The United Nations Security Council and the United Kingdom removed sanctions from an Iraqi entity this week. The designation targeted Iraq’s State Contracting Water and Sewage Projects Company.
The Bureau of Industry and Security will add four Myanmar entities to the Entity List June 6 for supporting the country’s Ministry of Defense, including through funding and the provision of telecommunication services. BIS will also correct the address for an existing Myanmar entity on the list. For each of the new entities, BIS will impose a license requirement for all items subject to the Export Administration Regulations, and no license exceptions will be available. The entities will be subject to a license review policy of presumption of denial.
KPMG recently surveyed a range of companies about their export control and sanctions compliance programs to determine how they organize those programs, which regulations and regions are their focus, and how they manage compliance risks. The survey, released last month, shows that compliance officials often manage multiple export regimes and nearly 90% of the respondents have a person or team “specially dedicated” to export compliance. About 25% don’t have or don’t know if they have a formal compliance program. In addition, about 99% said U.S. regulations affect their compliance, while 72% said they are affected by European Union laws and 46% by Chinese regulations. The survey also includes company responses to questions about risk assessments, training, screening activities and export licensing responsibilities.
The Financial Crimes Enforcement Network issued its first set of national anti-money laundering and anti-terrorism financing priorities, identifying corruption, cyber crime, drug trafficking and other activities that pose the biggest threats to the U.S. The priorities, issued June 30 and required by the Anti-Money Laundering Act of 2020, will be followed by a set of regulations and revisions to the Bank Secrecy Act, several U.S. agencies said in a joint statement.
A shift toward list-based sanctions and a rise in federal government compliance expectations are causing increasing challenges for the compliance community, compliance professionals said. At the center of those challenges are the designations imposed by the Treasury Department’s Office of Foreign Assets Control, which is setting a high bar for due diligence by more clearly describing its compliance expectations in settlement agreements.
Hong Kong this month updated its export control lists for certain chemical weapons and strategic commodities to align its regulations with multilateral export control groups. The revisions reflect control changes recently made by the Wassenaar Arrangement, the Nuclear Suppliers Group, the Missile Technology Control Regime, the Australia Group and the Chemical Weapons Convention, Hong Kong’s Trade and Industry Department said June 11. Hong Kong said it added controls on four sets of “toxic chemicals” and newly developed technologies such as “read-out integrated circuits” used for “night vision capability.” It also “relaxed controls” on some dual-use items, including “signal analysers, supercomputer, [and] radio equipment having quadrature amplitude modulation (QAM) techniques.”
The Bureau of Industry and Security fined a Fredericksburg, Virginia, military equipment manufacturer $200,000 for illegally exporting military-related items to military end-users in Russia, BIS said in a June 28 order. The company, Patriot 3, exported maritime jet boots with underwater propulsion systems despite having “knowledge” that the shipment violated the Export Administration Regulations, the order said. BIS said the boots, which were worth about $330,000 and exported in 2014, were controlled in connection with exports to military end-users or for military end-uses in Russia. Patriot 3 sent the boots to the Russian government’s Federal Guard Service, BIS said.
The Office of Foreign Assets Control on June 28 updated a Belarus-related entry on its Specially Designated Nationals List. The update made changes to the entry for Oleg Leonidovich Slizhevsky, head of the Belarus Public Associations Department at the Ministry of Justice.
Export Compliance Daily is providing readers with the top stories for June 21-25 in case you missed them. You can find any article by searching on the title or by clicking on the hyperlinked reference number.
The U.S. and its allies should expand sanctions and continue cutting off China from sensitive technologies as it further undermines democracy in Hong Kong, experts and a U.S. lawmaker said. They also said the U.S. should consider making China meet certain human rights standards before allowing companies to do business there and should work closer with European partners to close off Chinese access to global markets.