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Export Controls & Sanctions Watch - Edition 30-24

The Export Control & Sanctions Watch is a comprehensive, up-to-date resource that delivers the latest export control, sanctions, and AML updates, essential for customs professionals to maintain compliance and effectively manage trade risks.


LINK TO DOWNLOAD "THE EXPORT CONTROL & SANCTIONS WATCH" BELOW


Dear Reader of the Export Control & Sanctions Watch


This week's edition of The Export Control & Sanctions Watch covers essential updates in Anti-Money Laundering (AML), including a detailed introduction to AML's significance in export compliance, and key guidance such as the Beneficial Ownership Reporting Outreach and Education Toolkit, aimed at assisting small businesses.


Several blogs dive into critical AML topics like compliance challenges, KYC risk ratings, and the EU's creation of a new AML authority, providing thought leadership on how to maintain robust AML frameworks.


The UK has introduced a new Standard Individual Export Licence (SIEL) application portal, covering various licenses, including those related to sanctioned destinations like Russia and Iran. Additionally, the US has renewed export privilege denials for three Russian airlines due to ongoing violations of export regulations. Resources for export control professionals are highlighted, offering guidance on UK SIEL applications and US export control lists.



In sanctions updates, the G7 released new guidance to prevent Russian sanctions evasion, while the US updated corporate compliance guidance, emphasising proactive risk management. Sanctions have been imposed on leaders of Colombia's Clan del Golfo and Mexican entities involved in drug trafficking. Other significant developments include the UK updating sanctions against Iran and Guinea-Bissau, and the US addressing IT services and sanctions evasion schemes between Russia and North Korea.


We have also begun to add links to our add our thought leadership, guidance and explainer blogs and articles into this edition as standing items to turn this update into an even more valuable resource and we invite you to explore them all


I wish you an interesting lecture, and please let me have your comments at info@customsmanager.org 

 

Best regards

Arne





AML

Introduction to Anti-Money Laundering (AML)

Anti-money laundering (AML) is vital for export compliance professionals to safeguard against financial crimes. This blog covers the importance of AML in international trade, risks to watch for, and actionable best practices to protect your organisation and ensure compliance with regulations. We have written a thorough introduction to the subject.


Updates

Explanatory Note: This toolkit is a resource for educating small business owners about new beneficial ownership reporting requirements mandated by the bipartisan Corporate Transparency Act. The templates and sample content have been structured so you can easily tailor the message for your organisation. Toolkit Contents:

  • Frequently Asked Questions

  • Resources and How to Contact - FinCEN

  • Newsletter, Website, and Email Templates

  • Sample Social Media Posts

  • Sample Social Media Images


Compilation of all our AML Articles

We have written several blogs and articles on AML and we invite you to explore them all in this compilation: Link


Advice, Guidance & Thought Leadership on AML


Export Controls

25 September 2024: New SIEL Application Page


The UK started a new portal for standard individual export licence (SIEL) applications. Use this service to:

  • apply for an SIEL to export goods or products

  • edit or check an application

  • View your existing SIELs

Apply on the SPIRE system for:

  • temporary SIELs with multiple end-users  

  • transhipment SIELs

  • SIELs for Category 0 goods, software and technology

  • applications to certain sanctioned destinations:

    • Belarus

    • Iran

    • Iraq

    • Lebanon

    • Libya

    • Burma (Myanmar)

    • North Korea (DPRK)

    • Russia

    • Syria

    • Venezuela

    • Zimbabwe


Explanatory Note: The US Bureau of Industry and Security (BIS) has renewed its temporary denial of export privileges for 3 Russian airlines UTair Aviation JSC; Azur Air; and PJSC Aeroflot. BIS found it appropriate to renew TDOs for each company due to an alleged pattern of repeated/ongoing apparent violations of the EAR.


Resources for Export Control Professionals

UK: How to contact the Export Control Authority ECJU (help desk team) - email: exportcontrol.help@businessandtrade.gov.uk - phone: 020 7215 4594

U.S.: U.S. Export Controls: Complete Knowledge (Unlock the essentials of U.S. export controls with our comprehensive collection of links, covering laws, guidance, and sanctions lists for seamless compliance)

U.S: Where can I find the U.S. Export control/items lists?


Advice, Guidance & Thought Leadership on Export Controls



Updates in Sanctions: Sanctioning States


General


European Union

Advice, Guidance & Thought Leadership on UK Sanctions Policy and Law


United Kingdom

Advice, Guidance & Thought Leadership on UK Sanctions Policy and Law


United States

Updates

Explanatory Note: In 2023, the G7 introduced the Enforcement Coordination Mechanism (ECM) to enhance compliance and prevent the diversion of controlled items to Russia. This coordinated effort provides industries with practical guidance, including a list of high-risk items, red flag indicators, best practices, and screening tools to prevent sanctions evasion and strengthen compliance. The Group of Seven, consisting of Canada, France, Germany, Italy, Japan, the United Kingdom, the United States, and the EU, released its first-ever joint guidance aimed at safeguarding high-priority items, protecting businesses from reputational damage, and reducing liability risks. This guidance emphasizes identifying high-risk items, recognizing red flags of potential evasion, and implementing best practices to ensure sanctions' effectiveness.


Explanatory Note: The U.S. Department of Justice (DOJ) has updated its guidance on evaluating corporate compliance programs, emphasizing the need for companies to proactively adapt to emerging risks and misconduct. The revised guidance centers on three critical questions for evaluators: Is the compliance program well-designed? Is it being implemented with commitment and adequate resources? And, does it function effectively in practice? Key updates focus on using data and technology to detect early misconduct, conducting dynamic risk assessments, fostering employee accountability, and ensuring swift compliance integration after acquisitions. Organisations are also expected to continuously monitor and improve their programs to address evolving risks and regulatory changes. In light of heightened regulatory scrutiny, businesses must strengthen their compliance frameworks accordingly


Advice, Guidance & Thought Leadership on U.S Sanctions Policy and Law


Updates in Sanctions Topics: Narcotics

Explanatory Note:

Sanctioned individuals:

  • Jose Miguel Demoya Hernandez

  • Alexander Celis Durango

  • Jose Gonzalo Sanchez Sanches

  • Jose Emilson Cordoba Quinto

  • Wilder de Jesus Alcaraz Morales

  • Allegations: These individuals are allegedly leaders of the Clan del Golfo, a drug cartel involved in smuggling cocaine from Colombia to Central America.

Sanctioned entities:

  • Nieves y Paletas EVI: Owned by Jesus Norberto Larranaga Herrera and Karla Gabriela Lizarraga Sanchez, members of the Sinaloa cartel, designated in March 2024.

  • Farmacia y Mini Super Trinidad: Owned and controlled by Jose Arnoldo Morgan Huerta, a drug trafficker, designated in November 2023.

  • Allegations: Both entities were created using proceeds from drug trafficking activities.


Updates for Sanctioned Countries: DPRK

Democratic People's Republic of Korea (DPRK – North Korea)

Explanatory Note: On September 20, 2024, the UK Government amended the entry for Ri Pyong Chul on the UK sanctions list. This individual remains subject to an assets freeze.


Updates for Sanctioned Countries: Guinea-Bissau

Guinea-Bissau

Updates

Explanatory Note: The EU has deleted the following three entries from its Guinea-Bissau list:

  • Lieutenant Julio Na Man;

  • Tchipa Na Bidon; and

  • Idrissa Djalό.

All three were designated in 2012 as “Military Command” members responsible for the 2012 coup d’etat in Guinea-Bissau.

Guidance


Updates for Sanctioned Countries: Iran

Iran

23 September 2024: UK updates Iran sanctions

Explanatory Note: On September 19, 2024, the UK Government updated its Iran sanctions guidance to reflect updates made to the Iran sanctions regime under the Iran (Sanctions) (Amendment) Regulations 2024.  These regulations expand the trade sanctions against Iran, with the aim of disrupting Iran's Unmanned Aerial Vehicle and missile industry.  In particular, the regulations prohibit the export, supply and delivery and making available of additional goods and technology used by Iran to produce Advanced Conventional Weapons as well as the provision of ancillary services (brokering services, technical assistance, financial services etc

Applicable Sanctions Against Iran


Updates for Sanctioned Countries: Russia

Russia

26 September 2024: US Issues New Russia-Related FAQs on US-Owned Subsidiaries

Explanatory Note: The Department of the Treasury's Office of Foreign Assets Control (OFAC) is issuing three new, Russia-related Frequently Asked Questions (FAQs): FAQ 1193, FAQ 1194, and FAQ 1195, which address IT and software services involving U.S.-owned subsidiaries.

  • FAQ 1193: U.S. companies with subsidiaries in Russia may provide prohibited IT and software services to employees or contractors in Russia, but only if these services fall within their scope of employment with the U.S. subsidiary.

  • FAQ 1194: If a U.S. company has a subsidiary in a third country (outside Russia), it cannot provide prohibited IT and software services to employees or contractors located in Russia, even if they work for the subsidiary. OFAC may consider specific licenses on a case-by-case basis.

  • FAQ 1195: U.S. companies are prohibited from providing IT and software services to employees or contractors based in Russia if they work directly for the U.S. company. However, specific licenses may be applied for in such cases.

  • In this weekly update, we summarise the most notable updates in the UK sanctions world. If you have any questions in respect of any of the developments set out below, please do not hesitate to contact a member of our London Global and Government Trade team listed above.


Explanatory Note: The UK Government updated a factsheet setting out the UK’s support to Ukraine.  Among other things, the factsheet states that the UK has sanctioned over 2,000 individuals and entities, 1,700 of which have been sanctioned since Russia's full-scale invasion, and on September 11, 2024, the UK announced sanctions on another 10 vessels in Russia’s “shadow fleet”.


Explanatory Note: OFAC designated a network of five entities and one individual—involved in a Russia/DPRK payment scheme that has enabled and supported ongoing efforts to establish illicit payment mechanisms between Russia and the Democratic People’s Republic of Korea (DPRK). Entities and individuals concerned:

  •  Dmitry Yuryevich Nikulin

  •  MRB Bank

  •  STROYTREYD LLC

  •  TIMER Bank, AO

  •  Korea Kwangson Banking Corp

  •  Russian Financial Corporation

  •  Trans Kapital Limited Liability Company

  •  TSMRBANK, OOO

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