A recent joint alert by the Commerce and Treasury departments has been a boon to industry and the government, and has given export control officers more leads to track down potential Russia violations, said Matthew Axelrod, Commerce’s top export enforcement official. Axelrod said the alert has been so successful that the two agencies are hoping to publish another one next year.
The U.K. adopted new financial and trade sanctions against Russia Dec. 15, barring the provision of trust services to, or for the benefit of, a designated individual or entity, and the provision of new trust services to or for the benefit of, a person connected with Russia. The restrictions further amend existing sanctions on securities or money market instruments and loans and credit arrangements to a person linked to Russia, as well as suspend the Bank of England's duty to "make a decision in respect of a notification of third-country resolution action in respect of designated persons or persons owned or controlled by designated persons."
The Office of Foreign Assets Control designated 18 entities related to Russia's financial services sector, according to a Dec. 15 press release. The State Department also issued a set of Russia sanctions, primarily targeting oligarch Vladimir Potanin, three members of his immediate family and his business network, the department said in a Dec. 15 press release.
The Bureau of Industry and Security added a host of Chinese and Russian entities to the Entity List, including top Chinese chipmaker Yangtze Memory Technologies Co. and leading Chinese artificial intelligence firms, the agency said in a pair of notices released Dec. 15. The new restrictions on the Chinese firms are aimed at “severely restricting” China’s ability to leverage AI, advanced computing and other commercial technologies for its military or human rights abuses, BIS Undersecretary Alan Estevez said. The agency added the Russian entities to the list after it was unable to complete end-use checks. The changes took effect Dec. 16.
The Bureau of Industry and Security will add a host of Chinese and Russian entities to the Entity List, including top Chinese chipmaker Yangtze Memory Technologies Co., the agency said in a pair of notices released Dec. 15.
The U.K. added 15 individuals and one entity to its Russia sanctions regime Dec. 13, the Office of Financial Sanctions Implementation announced. The individuals are businessmen and government officials responsible for arming the Russian military with unmanned aerial vehicles for the war in Ukraine. The entity is Oje Parvaz Mado Nafar Co., an Iranian business that provides UAVs for the Russian military. The Dec. 13 notice also amended the entry for Said Mikhailovich Gutseriev.
The EU added 24 individuals and five entities to its sanctions regime against Iran in response to the repression of ongoing protests and provision of military assistance to Russia. Twenty of the individuals and one of the entities were subjected to an asset freeze and travel ban for aiding in the crackdown on protests following the death of Mahsa Amini, the European Council said. Four of the individuals and four of the entities were added to the restrictions list for their role in supplying Russia with unmanned aerial vehicles to aid in the war against Ukraine. The council said it plans to impose sanctions on another entity for these same reasons.
The Bureau of Industry and Security issued a 180-day temporary denial order this week against three people and two companies for illegally sending controlled exports to Russia as part of a Moscow-led sanctions evasion scheme. Along with the denial order, DOJ indicted the three people, along with others, on charges related to the illegal exports, including money laundering, wire fraud, bank fraud and conspiring to defraud the U.S.
Assistant Attorney General Kenneth Polite last week touted DOJ's action under the Foreign Corrupt Practices Act, championing DOJ's $315 million FCPA resolution with ABB over the company's bribery of an official in South Africa's state-owned energy company (see 2212050021). The case was the department's "first coordinated resolution with authorities in South Africa," and has resulted in South African authorities bringing corruption charges of their own against the official, Polite said in closing remarks, as prepared for delivery, Dec. 9 at an anti-corruption conference.
Allied export control authorities should be more nimble, harmonized and coordinated to maximize their effectiveness, particularly around Russia restrictions, said Kevin Wolf, a former senior U.S. export control official. In written comments last week to the U.K. Parliament’s arms export control committees, Wolf also said the U.K. and other countries can improve their export enforcement efforts against Russia, including by creating incentives for companies to “enhance” their compliance programs, dedicating more resources to study Russian sanctions evasion and working together to create a “standard structure of export control violations.”