The United Kingdom's Office of Financial Sanctions Implementation released a Dec. 17 guidance on determining whether a sanctioned entity is involved in a transaction. The guidance contains links to OFSI’s consolidated list and describes difficulties that may rise when screening certain companies, including complicated ownership stakes and the use of shell companies. The guidance details a case study involving the Libya African Investment Portfolio and the Libyan Investment Authority, two sanctioned entities with hotel subsidiaries that may avoid screening detection. The guidance also offers advice for steps to take after discovering a sanctioned entity in a transaction.
The State Department issued a Dec. 16 sanctions advisory about exports of graphite electrodes and needle coke to Iran, saying those materials subject exporters to “significant sanctions risk.” Both materials are “essential” to Iran’s steel industry, the State Department said, which is sanctioned by the U.S. Sanctions extend to producers and exporters of the materials along with “port operators, shippers, shipping companies, and vessel operators and owners,” who may be subject to blocking sanctions, even if the intended end-user is not in Iran’s steel sector.
China and Russia proposed a draft resolution to the United Nations Security Council to ease sanctions on North Korea, a spokesman for China’s Foreign Ministry said at a Dec. 17 press conference. China said it wants to denuclearize the Korean peninsula through continued negotiations between the U.S. and North Korea, which should result in the removal of sanctions. “Some sanctions should be lifted in light of [North Korea’s] compliance with relevant resolutions,” the spokesman said. “China hopes the Security Council members will … support the draft resolution proposed by China and Russia and jointly work for political settlement of the Peninsula issue.” Along with lifting sanctions, the proposal submitted by China and Russia calls for the removal of a ban on North Korean exports of statues, seafood and textiles, according to a Dec. 17 report from Reuters.
Export Compliance Daily is providing readers with some of the top stories for Dec. 9-13 in case you missed them.
The Treasury’s Office of Foreign Assets Control is expected to increase enforcement of its 50 percent rule, placing more of a burden on companies to determine whether they are indirectly dealing with a sanctioned party, said Joshua Shrager, a former Treasury official and a senior specialist with Kharon, a sanctions advisory firm. While the 50 percent rule -- which bans transactions with a company owned 50 percent or more by a sanctioned party -- is growing increasingly complicated due to a rise in U.S. sanctions, OFAC’s compliance expectations are rising too, Shrager said.
Japan and South Korea met Dec. 16 for another export control policy dialogue to discuss their ongoing trade dispute (see 1907010020), Japan’s Ministry of Economy, Trade and Industry said in a press release. Japan said the two sides discussed “circumstances” surrounding critical technology controls and their export control systems, and agreed to continue talks to “contribute to resolving issues of concern.” The meeting was aimed at better understanding each other’s export control measures, Japan said. The two sides previously met for two rounds of consultations at the World Trade Organization (see 1911080022).
A bipartisan group of more than 45 lawmakers urged the Trump administration to impose strict sanctions on China’s treatment of its Uighur population, saying the October addition of 28 Chinese entities to the Commerce Department’s Entity List (see 1910070076) was not enough. “These measures were a first step that do not go far enough in ensuring accountability for China’s government and Communist Party,” the lawmakers said in a Dec. 12 letter to Secretary of State Mike Pompeo, Treasury Secretary Steven Mnuchin and Commerce Secretary Wilbur Ross.
The Treasury’s Office of Foreign Assets Control sanctioned two South Sudan officials for obstructing peace talks, Treasury said in a Dec. 16 press release. OFAC targeted the Minister of Cabinet Affairs Martin Elia Lomuro and Minister of Defense and Veteran Affairs Kuol Manyang Juuk, who have both “perpetuated” the country’s “conflict for their own personal enrichment,” the press release said.
The European Union will renew sanctions against Russia for another six months, the European Council decided Dec. 13, according to a press release. The sanctions, targeting Russia’s financial, energy and defense sectors, were due to expire in January, according to the EU Sanctions blog.
Sen. Bob Menendez, D-N.J., for a second time announced he will block the Trump administration’s efforts to transfer export controls of firearms from the State Department to the Commerce Department, according to a Dec. 13 press release. In a Dec. 10 letter to Secretary of State Mike Pompeo, Menendez said the military items should not be removed from the State Department’s U.S. Munitions List and should instead be subject to “more rigorous controls” and oversight. The senator previously announced a hold on the transfer in February (see 1903060021).