The Bureau of Industry and Security this week released a range of updates to its Oct. 7, 2022, China chip controls, unveiling two rules that will impose new license requirements on additional chips and chipmaking tools, make revisions to its U.S. persons restrictions, expand licensing requirements for exports of certain chipmaking items to U.S. arms-embargoed countries, create a new notification requirement and introduce other measures to address export control circumvention risks.
The U.S. has little room to expand sanctions against Hamas, but it could look to track down and designate additional front companies the terror group uses to fund its activities, said Jason Prince, former chief counsel at the Office of Foreign Assets Control. Although OFAC has general licenses in place to authorize a broad range of humanitarian-related transactions involving Palestine, Hamas’ designation as a foreign terrorist organization could make some financial institutions less willing to approve those aid-related transactions, Prince said.
The Bureau of Industry and Security officially released the texts of two rules to update its Oct. 7, 2022, China chip controls, including an interim final rule that will update controls on certain semiconductor manufacturing items and another interim final rule that will update restrictions on certain advanced computing items, supercomputer and semiconductor end-uses and make other updates and corrections.
The Treasury Department this week sanctioned two ship owners in Turkey and the United Arab Emirates, along with their two vessels, for transporting Russian oil sold above the global price cap set by the U.S. and its allies. The agency also issued a new general license authorizing certain transactions with the two sanctioned ship owners and, together with the Group of 7 countries and Australia, published a new price cap guidance and advisory outlining best practices for the maritime oil industry.
The U.K.'s Office of Financial Sanctions Implementation on Oct. 10 extended a General License allowing U.K. parties to receive payments from a sanctioned party if the contract took effect before the party's designation. The license now runs through May 21. OFSI also altered the license to change the definition of "contractual obligation" to exclude contracts using certain types of financial instruments, expand the list of excluded contracts that involve financial instruments, and create another annex that lists other types of excluded contracts.
Farhad Nafeiy, a California-based telecommunications consultant, pleaded guilty this week to violating the International Emergency Economic Powers Act after he breached the scope of sanctions licenses from the Office of Foreign Assets Control.
The U.K. issued a General License Sept. 29 under its Russia sanctions regime to provide certainty that a credit or financial institution can return a payment to another such institution which has been processed by a sanctioned credit or financial institution at some point in the payment chain. The license applies when the sanctioned party acted as an original, correspondent or intermediary institution where the recipient institution and the institution that sent the payment are not designated parties, and the original account holder and the original intended recipient are not sanctioned parties. The license expires at the end of the day on Dec. 1.
LONDON -- The State Department hasn’t yet seen much participation in its open general license pilot program despite releasing the licenses more than a year ago, said Catherine Hamilton, the licensing director for the agency’s Directorate of Defense Trade Controls. Hamilton said the licenses specifically aren’t “really being used in the U.K. as we had envisioned.”
The Office of Foreign Assets Control published two previously issued general licenses under its Russian Harmful Foreign Activities Sanctions Regulations. The full text of each license is available in the notice.
Global manufacturing firm 3M reached a $9.6 million settlement with the Office of Foreign Assets Control this week after it allegedly violated U.S. sanctions on Iran. OFAC said the company’s Swiss subsidiary knowingly sold reflective license plate sheeting through a German reseller to Bonyad Taavon Naja, an entity controlled by Iran’s Law Enforcement Forces.