The Census Bureau released the November edition of its Automated Export System (AES) Newsletter, which includes articles on Export Control Reform and the Consolidated Proscribed Party Screening List; suppressing AES fatal errors; and reporting Transportation Reference Numbers. Highlights of the newsletter are as follows:
A Taiwanese national was sentenced to two years in prison Oct. 24 for helping to obtain and export military sensitive parts for Iran, in violation of the Iranian trade embargo, said Immigration and Customs Enforcement. The indictment charged Susan Yip, 35, a citizen of Taiwan, along with Mehrdad Foomanie (aka Frank Foomanie) of Iran, and Merdad Ansari of the United Arab Emirates, with conspiracy to violate the Iranian Transaction Regulations, conspiracy to launder money and conspiracy to commit wire fraud. Yip had pleaded guilty to the conspiracy charge July 20, admitting that from Oct. 9, 2007 to June 15, 2011, she acted as a broker and conduit for Foomanie to buy items in the United States and have them unlawfully shipped to Iran.
The Treasury Department Office of Foreign Assets Control made some minor changes to the Iranian Transactions Regulations, 31 C.F.R. part 560, and provided some additional guidance on transactions with Iran, following enactment of new legislation in August. Among other things, it changed the name to the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (the "ITSR"), and amended the renamed ITSR to implement Executive Order 13599 (other than section 11) and sections 1245(c) and (d)(1)(B) of the National Defense Authorization Act for Fiscal Year 2012. These new regulations block the Government of Iran and all Iranian financial institutions and add numerous new sections to the ITSR, including prohibitions, definitions, interpretations, and licensing provisions. Also, a few general licenses that had been included in the Iranian Transactions Regulations have now been removed, OFAC said. OFAC also published a Statement of Licensing Procedure on Support of Human Rights-, Humanitarian-, and Democracy-Related Activities with Respect to Iran (here). The statement reflects procedures established pursuant to the Iran Threat Reduction and Syria Human Rights Act of 2012. OFAC provided a list of frequently asked questions pertaining to the ITSR and the Statement of Licensing Procedure (here). OFAC also published a list of the basic medical supplies that are eligible for export or reexport to Iran, subject to restrictions, under a new general license set forth in the ITSR (here). And it removed General License A and General License B to reflect the changes set forth in the ITSR.
The Treasury Department Office of Foreign Assets Control issued its Data Delivery Standards, describing the technical requirements for the preferred format in which to submit electronic document productions, including self-disclosures, administrative subpoena responses, and other documents or reports. It said producing documents in an electronic format is not required, but it prefers to receive information on digital media instead of hardcopy if the number of pages exceeds 500. The document said OFAC uses Concordance v10.012 and Concordance Image v5.09. General instructions include:
The following individuals have been added to OFAC's SDN List:
Medical supply company Brasseler USA of Savannah, Ga., agreed to pay $18,900 to settle potential civil liability for alleged violations of the Iranian Transactions Regulations from 2006 to 2009, said the Treasury Department Office of Foreign Assets Control. OFAC alleged that Brasseler exported goods or services to a person in a third country with knowledge or reason to know they were intended for transshipment to Iran, without authorization from OFAC. OFAC said Brasseler's conduct demonstrated reckless disregard for U.S. sanctions requirements, involved a pattern of concealment, and Brasseler did not have a compliance program in place.
The following individuals have been added to OFAC's SDN List:
The following entities have been added to OFAC's SDN List:
The following entities have been added to OFAC's SDN List:
President Barack Obama signed an executive order (here) authorizing new sanctions against Iran and Syria. The new order prohibits foreign subsidiaries of U.S. entities from knowingly violating the Iranian Transactions Regulations, E.O. 13599, section 5 of E.O. 13622, or Section 12 of the new E.O., and provides for civil penalties on the U.S. parent company for such violations. The Treasury Department issued a FAQ document (here) detailing the impact of the order.