Behrouz Mokhtari of McLean, Virginia, and Tehran pleaded guilty Jan. 9 to two conspiracies to violate U.S. sanctions on Iran "by engaging in business activities on behalf of Iranian entities" without getting a license from the Treasury Department's Office of Foreign Assets Control, DOJ announced Jan. 9. Mokhtari will forfeit money, property and assets obtained from the schemes, including a Campbell, California, home, and a money judgment of over $2.8 million, DOJ said. The defendant faces a maximum of five years in prison for each of the two conspiracy counts.
SDN List
The Office of Foreign Assets Control publishes a list of individuals and companies subject to sanctions imposed by the agency. Sanctioned parties are known as “Specially Designated Nationals,” and the list, one of several sanctions lists issued by OFAC, is called the SDN List. Assets of individuals and companies on the SDN List are generally blocked.
Electronics distribution company Broad Tech System and its president and owner, Tao Jiang of Riverside, California, pleaded guilty Jan. 11 to participating in a conspiracy to illegally ship chemicals made or distributed by a Rhode Island-based company to a Chinese firm with ties to the Chinese military, the U.S. Attorney's Office for the District of Rhode Island announced. Jiang and Broad Tech admitted to violating the Export Control Act and conspiring to commit money laundering.
The Office of Foreign Assets Control this week sanctioned one person, two entities and three aircraft with ties to Russia, according to a Jan. 11 update to its Specially Designated Nationals List. The designations target Vladimir Vladimirovich Mikheychik, Ashuluk Firing Range, and Vladimirovka Advanced Weapons and Research Complex. OFAC also sanctioned aircraft with tail numbers RF-78757, RF-82011 and RF-86898.
The Bureau of Industry and Security is working more closely with the Office of Foreign Assets Control on enforcement issues, which could allow the two agencies to better align the BIS Entity List and OFAC’s Specially Designated Nationals List, a BIS official said this week.
Licensing work at sanctions and export control agencies likely will grind to a near halt in the event of a federal government shutdown Oct. 1, though enforcement activities at the Bureau of Industry and Security, Directorate of Defense Trade Controls and Office of Foreign Assets Control will continue -- if previous shutdowns are any guide.
A former board member of a Russian state-owned bank asked a federal court to order the U.S. to remove her from a U.S. sanctions list, saying there is “no factual basis” that supports her listing. In a complaint recently filed with the U.S. District Court for the District of Columbia, Elena Titova, a dual Russian and U.K. citizen, said she resigned from her position eight days after Russia’s invasion of Ukraine last year but was still added to the Treasury Department’s Specially Designated Nationals List even though she hasn’t been designated by any “other nation in the world.”
The U.S. this week announced new Russia-related trade restrictions, adding 28 entities to the Commerce Department’s Entity List and more than 100 entries to the Treasury Department’s Specially Designated Nationals List. The measures target people and companies either operating in Russia, aiding the country’s war against Ukraine or helping Moscow evade sanctions.
The Office of Foreign Assets Control this week added one entry to its Specially Designated Nationals List for counter-terrorism reasons and updated two other entries. Sanctions now apply to Sami Mahmud Mohammed al-Uraydi. OFAC didn’t immediately provide more information and directed questions to the State Department. A State Department spokesperson didn’t comment.
Although many of the U.S. sanctions against Russia have been in place for months, companies are still dealing with a range of compliance challenges, Crowell & Moring trade lawyers said this week, especially involving Russia-related service restrictions. They also said they don’t expect the pace of sanctions to slow anytime soon, especially as the U.S. ramps up enforcement efforts this year.
The Office of Foreign Assets Control Dec. 30 fined a multinational Danish-based refrigeration manufacturer more than $4.3 million for violating U.S. sanctions against Iran, Syria and Sudan. Danfoss, which also sells air conditioners and other cooling and heating products, illegally directed customers in all three countries to make payments through a U.S. financial institution, OFAC said in an enforcement notice. The company also made illegal payments to entities in Iran and Syria.