A Lebanese energy equipment company was fined $368,000 by the Bureau of Industry and Security after it illegally reexported generators to Syria, according to a settlement agreement signed Nov. 27. Ghaddar Machinery allegedly committed 20 violations of the Export Administration Regulations from 2014 to 2016, totaling about $730,000 worth of exports, BIS said. Ghaddar agreed to pay the penalty in five installments through November 2021. Failure to make the payments could result in more penalties, according to the settlement agreement, including a two-year denial of export privileges.
Iran Export Controls
Certain items on the Commerce Control List require a license from BIS to export them to Iran. The Iranian Transactions Sanctions Regulations (ITSR) (31 CFR Part 560) also prohibit the export and reexport of goods to Iran subject to EAR.
An Iranian businessman was sentenced to 46 months in prison for illegally exporting carbon fiber from the U.S. to Iran, the Justice Department said Nov. 14. Behzad Pourghannad worked with two others between 2008 and 2013 to export the carbon fiber to Iran from third countries using falsified documents and front companies, the agency said.
Apple was fined about $465,000 for violations of the Foreign Narcotics Kingpin Sanctions Regulations after it hosted, sold and “facilitated the transfer” of software applications and content belonging to a sanctioned company, the Treasury’s Office of Foreign Assets Control said in a Nov. 25 notice. Apple allegedly dealt in “the property and interests” of SIS d.o.o., a Slovenian software company added to OFAC’s Specially Designated Nationals List in 2015.
The State Department issued notices of its report to Congress under the Iran Freedom and Counter-Proliferation Act, which requires the State and Treasury Departments to assess where Iran is buying sensitive materials for its nuclear program and which sectors of its economy are being controlled by the country’s military.
A U.S. electronics and computer component company may have violated U.S. sanctions on Iran and Syria, the company said in a Nov. 7 filing with the Securities and Exchange Commission. Colorado-based Arrow Electronics said a “limited number of non-executive employees … facilitated product shipment” to customers for re-export to people covered by U.S. sanctions on Iran and Syria. The transactions took place between 2015 and 2019 and were valued at about $5,000, the company said. Arrow Electronics said it voluntarily disclosed the potential violations to the Treasury’s Office of Foreign Assets Controls and the Commerce Department Bureau of Industry and Security earlier this year. It also disciplined or fired employees involved in the transactions and said it plans to “cooperate fully” with BIS and OFAC. The company said it is not able to “estimate” the potential penalty it may receive.
The Bureau of Industry and Security updated its Entity List by adding 22 entities, updating one entry and removing three entries, BIS said. The added entities include freight forwarding and logistics companies and a medical instrument supplier.
The Treasury’s Office of Foreign Assets Control released quarterly reports of licensing activities for certain authorizations to Iran and Sudan from January through September 2018, OFAC said in a Nov. 5 notice. The report provides information on license applications for exports of agricultural commodities, medicine, and medical devices to Iran and Sudan under the licensing regime in the Trade Sanctions Reform and Export Enforcement Act of 2000, OFAC said. The reports contain statistics on the number of license applications and licenses issued for each product, the number of applications and licenses issued for each country and more.
Export Compliance Daily is providing readers with some of the top stories for Oct. 21-25 in case they were missed.
The Treasury Department announced a mechanism to help companies ensure their humanitarian exports to Iran will not be diverted to the government and other sanctioned Iranian entities, Treasury said in an Oct. 25 press release. The mechanism will require participating foreign governments and financial institutions to “conduct enhanced due diligence” -- including the reporting of “a substantial and unprecedented amount of information” -- on a monthly basis. Treasury’s Office of Foreign Assets Control also issued a guidance outlining the requirements.
Former National Security Adviser John Bolton said U.S. sanctions are not being enforced effectively and criticized what he said is a lack of U.S. involvement in the Japan-South Korea trade dispute.