The U.K. on Oct. 7 updated its end-user undertaking form -- which must be completed by all exporters to comply with standard individual export licences and standard individual trade control licences terms and conditions -- to remove references to its outgoing licensing system SPIRE. The country plans to retire SPIRE, or the Shared Primary Information Resource Environment, and replace it with its new digital export licensing system, Licensing for International Trade (LITE), in the coming months (see 2409190037).
Senate Foreign Relations Committee ranking member Sen. Jim Risch, R-Idaho, urged his colleagues last week to approve his Strategic Act, a wide-ranging China bill that contains several export control, sanctions and foreign investment provisions, including creation of a “tiger team” to start identifying targets for sanctions, export controls and other economic measures “well before China takes military action” against Taiwan.
The Office of Foreign Assets Control this week sanctioned three people and a “sham charity” that it said are international financial supporters of the terror group Hamas. It also designated a “longstanding” Hamas supporter and nine of his businesses for their ties to the group. OFAC said they each “play critical roles in external fundraising” for Hamas, often by disguising their support as charity.
The State Department’s Directorate of Defense Trade Controls recently updated its list of commodity jurisdiction (CJ) determinations, which DDTC issues after receiving requests from industry to determine whether a commodity or service is covered by the U.S. Munitions List. The table includes several new CJ determinations issued in September, including certain subassemblies for tactical unmanned aerial vehicles, which DDTC classified as USML Category VIII(f); an item that allows helicopters to carry sling loads and serves as “a conduit for electric actuation of remote hooks and other electrically operated equipment,” which it classified under the Export Administration Regulations as EAR99; and a digital fuel gauge that it classified as USML Category VIII(h)(1).
The Office of Foreign Assets Control this week made several revisions to a May rule that updated its reporting, procedures and penalties regulations (see 2405080023), and offered guidance on how banks and their customers should treat cases in which a bank accidentally blocks funds because of mistaken identity or other errors.
The U.K. last week issued new guidance about the information-sharing provisions in its Economic Crime and Corporate Transparency Act, a law meant to increase detection and enforcement of sanctions evasion, terrorism financing, money laundering and other economic crimes. The guidance outlines the “voluntary” measures within the law that are designed to give “greater clarity and comfort” to companies when sharing information about potentially risky customers, the U.K. said, and describes how companies “can ensure that they are protected by the provisions when undertaking direct and indirect sharing.”
Four Kentucky residents were arrested on Oct. 4 after conspiring to ship firearms to Iraq without obtaining an export license, DOJ said. They were indicted on conspiracy to violate the Export Control Reform Act and smuggle goods from the U.S., among other charges.
The Bureau of Industry and Security on Oct. 4 again renewed the temporary denial order for Russian airline Ural Airlines, saying it has continued to illegally operate aircraft on flights within Russia and to and from Tajikistan and Kyrgyzstan. The order, first issued in October 2022 (see 2210170009) and renewed twice (see 2310100017), bars the airline from participating in transactions with items subject to the Export Administration Regulations.
The Office of Foreign Assets Control may be preparing to increase its use of private blocking notices, which the agency sometimes sends to companies instead of publicly sanctioning a party on its Specially Designated Nationals List, Paul Weiss said in an October client alert.
The U.S. is increasingly expecting companies to monitor government guidance as well as export violations committed by others, and to use those cases as “lessons learned” to improve their own compliance programs, lawyers said this week.