The U.S. on Feb. 11 announced sanctions and export controls targeting the Myanmar military, defense ministry and security services after it carried out a coup earlier this month (see 2102100060). The White House also issued an executive order outlining a new Myanmar sanctions regime and said more restrictions will be imposed “in the coming days.”
OFAC
The Treasury Department's Office of Foreign Assets Control (OFAC) administers and enforces various economic and trade sanctions programs. It sanctions people and entities by adding them to the Specially Designated Nationals List, and it maintains several other restricted party lists, including the Non-SDN Chinese Military-Industrial Complex Companies List, which includes entities subject to certain investment restrictions.
A U.S. adhesive manufacturing company said it was issued a warning letter from the Treasury Department after disclosing potential violations of U.S. sanctions against Iran, according to the company’s Jan. 26 Securities and Exchange Commission filing. H.B. Fuller said customers of its subsidiaries in Turkey and India may have sold its hygiene products into Iran, which would have violated U.S. sanctions. The company said it disclosed the violations to the Office of Foreign Assets Control in 2018, and in December OFAC issued a cautionary letter with no penalty. H.B. Fuller said the transactions at the center of the potential violations represented less than 1% of the company’s 2018 net revenue.
Jenner & Block hired Rachel Alpert, previously with Latham & Watkins, as a partner, the firm said in a news release. Alpert also previously worked in the State Department Office of the Legal Adviser. Her work “supports organizations in the oil and gas, communications, travel, and other industries on legal issues involving export controls and US sanctions laws and regulations under the International Traffic in Arms Regulations (ITAR), Export Administration Regulations (EAR), and Office of Foreign Assets Control (OFAC) regulations,” Jenner & Block said.
The Office of Foreign Assets Control accepted a settlement from a French bank of than $8.5 million for apparent violations U.S. sanctions against Syria, OFAC said in a Jan. 4 notice. Union de Banques Arabes et Françaises (UBAF) operated U.S. dollar accounts for Syrian financial institutions and “indirectly conducted USD business” for those accounts on behalf of the institutions through the U.S. financial system, OFAC said. UBAF agreed to remit $8,572,500 to settle its potential civil liability for 127 “apparent violations.”
Four companies said they may have violated U.S. sanctions and export controls after providing products to blocked parties or not complying with licensing requirements, according to their Securities and Exchange Commission filings. The potential violations involve illegal exports of software, providing services to people in embargoed countries, and sanctioned airline activities.
The U.S. sanctioned eight people and 10 entities for being members of or supporting the Syrian government, the Treasury Department said Dec. 22. The sanctions designate two people and 10 entities by Treasury and six people by the State Department. Treasury also issued three new frequently asked questions related to Syria.
The Office of Foreign Assets Control sanctioned the China National Electronics Import & Export Corp. (CEIEC), a Chinese state-owned company that exports advanced technologies and technical expertise globally, OFAC said Nov. 30. The agency designated CEIEC for selling technology, software and training to Venezuelan government entities, which then use the products to bolster the Nicolas Maduro regime’s “malicious cyber efforts.”
While the Joe Biden administration will likely pursue more multilateral sanctions than the Trump administration, industry should not expect the Office of Foreign Assets Control to reverse its yearslong trend of increased sanctions, a former OFAC official and law firms said.
Airbnb may have violated U.S. sanctions laws and submitted a voluntary self-disclosure to the Office of Foreign Assets Control in September, the company said in a Nov. 16 Securities and Exchange Commission filing. Airbnb said it began an internal review in 2019 and has been cooperating with OFAC “regarding certain user activity on our platform” that was “inconsistent with our policies” and U.S. sanctions laws. The company said those activities involved Ukraine's Crimea region, Cuba and certain OFAC specially designated nationals.
The Office of Foreign Assets Control sanctioned 17 Syrian and Lebanese people and entities for operating in Syria’s oil industry and supporting the Bashar al-Assad’s regime oil production network, according to a Nov. 9 press release. The sanctions target Syrian military officials, members of Syria’s Parliament, Syrian government entities and both Syrian and Lebanese people trying to “revive Syria’s deteriorating petroleum industry,” OFAC said.