After current and former lawmakers asked the Treasury Department to clarify its stance on humanitarian exports to sanctioned countries, the agency pushed back on accusations that sanctions are stopping those exports, saying it does not target legitimate exported aid. Some of those accusations are marred by a misunderstanding of Treasury’s general licenses and exemptions, said sanctions lawyer Doug Jacobson: they do allow a broad range of humanitarian exports to countries like Iran.
The Treasury’s Office of Foreign Assets Control updated the North Korean Sanctions Regulations by adding new sanctions provisions and exemptions and amending the definition for “luxury goods,” according to a notice in the Federal Register. OFAC also made several technical edits to three definitions, revised an “interpretive provision” and updated the “authorities and delegations sections” of the regulations.
The Treasury’s Office of Foreign Assets Control is adjusting its civil monetary penalties for inflation, the agency said in a notice. The notice includes a table detailing the existing and new maximum penalty amounts.
The Treasury Office of Foreign Assets Control’s April 6 sanctions targeted a white supremacist group and its three leaders (see 2004060050), the State Department said April 6, announcing its own designation of the Russian Imperial Movement as a Specially Designated Global Terrorist. The sanctions against RIM marked the “first time the United States has ever designated foreign white supremacist terrorists,” State said. The group provides paramilitary-style training to Neo-Nazis and white supremacist, the agency said.
The U.S. should expand the scope of humanitarian license exceptions for exports to Iran and add staffing within the Treasury Department to speed up the licensing process, members of the European Leadership Network and The Iran Project said April 6. The statement, signed by 25 former U.S. and European government officials, also said the U.S. needs to do more to assure companies, banks and organizations they will not be targeted for exporting humanitarian items to Iran. The letter follows similar calls by U.S. lawmakers, who said sanctions are hindering life-saving exports to Iran (see 2004010019).
The Treasury’s Office of Foreign Assets Control added three Russian nationals and one Russian entity to its Specially Designated Nationals List, OFAC said in an April 6 notice. The sanctions target Denis Valiullovich Gariyev, Nikolay Nikolayevich Trushchalov, Stanislav Anatolyevich Vorobyev and the Russian Imperial Movement. OFAC did not immediately release more information on the designations.
The Federal Aviation Administration does not independently vet civil aircraft registrations, which could lead to a host of sanctions related risks, according to a March report from the Government Accountability Office. In at least one case, the FAA allowed a sanctioned Venezuelan drug trafficker to obtain a dealer certificate, which gave his front company access to blocked planes for more than a year, the GAO said. FAA officials said they do not have the required authorities to address sanctions issues, but the GAO pointed to a lack of coordination between FAA and the Treasury's Office of Foreign Assets Control and a flawed FAA registration system.
The Treasury’s Office of Foreign Assets Control extended the expiration date for a Venezuela-related general license, OFAC said in an April 3 notice. General License No. 13E, which replaces No. 13D (see 1910170057), authorizes certain transactions involving Nynas AB, a joint venture between biofuel producer Neste and Petroleos de Venezuela, Venezuela's state-run oil company. OFAC extended the expiration because Nynas is discussing with OFAC a “proposed corporate restructuring” that could “result in significant changes to Nynas AB’s ownership and control,” the notice said, and the expiration will “afford additional time to complete this engagement.” The license, which was scheduled to expire April 14, will now expire May 14.
Companies involved in sanctions compliance should closely communicate with regulators during the COVID-19 pandemic and carefully document compliance procedures during work-from-home operations, according to Nicole Sayegh Succar, a trade lawyer with Crowell & Moring. Those steps could minimize scrutiny and potential sanctions penalties after the pandemic subsides, Succar said during an April 2 webinar hosted by the law firm.
The Trump administration should issue “broad licenses” to medical companies and create dedicated channels for industry to export medical goods to Iran during the COVID-19 pandemic, former Vice President Joe Biden said April 2. Although the Treasury's Office of Foreign Assets Control already has broad general licenses that allow exemptions for humanitarian exports, Biden said they are not effective. “In practice, most governments and organizations are too concerned about running afoul of U.S. sanctions to offer assistance,” Biden said. “As a result, our sanctions are limiting Iran’s access to medical supplies and needed equipment.”