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The Export Controls & Sanction Manager Edition 2

Edition 2 - 2024 - Week 2 of your blog-style magazine on export controls & sanctions.

The period covered 09.01.2024-15.01.2024



A word from the editor

Introducing the second edition of "The Export Controls & Sanctions" Manager Magazine for the year. Our magazine supports compliance with export controls and sanctions in numerous countries.


This week, we look at the US Treasury which has imposed additional sanctions on the primary financial supporter of Yemen's Houthi rebel group, as well as a fleet of ships utilised for fundraising purposes. Following the airstrikes by the US and UK on Houthi sites in Yemen, the Iranian-backed rebel group retaliated by targeting ships passing through the Red Sea en route to the Suez Canal. The sanctions are aimed at disrupting the financial networks that support Houthi militants in Iran. We thoroughly analyse these punishments in this issue. In this context, check out the "UK and International Response to Houthis in the Red Sea 2024" study from the UK, providing comprehensive insights (see below).


EU sanctions aim to address the challenging situation in Guatemala. Have a look at what the EU is planning below.


Finally, from China's Ministry of Commerce, the US has been accused of weaponizing export regulations. Retrieve the information that was mentioned.


There is undoubtedly much more to explore in this edition. Also, take a look at our comprehensive export control and sanctions training. Exciting news! Fresh 2024 courses have just been released.

Deliver an engaging and captivating lecture! Do you have any questions? Can I get some feedback? Contact us at info@customsmanager.org.


Arne


Starting this Friday, a new premium plan customers will be required to purchase an additional plan in order to access export control & sanctions information behind the barrier. Select from options of weekly, monthly, or yearly. If you sign up for our premium plan before that date, you can receive both magazines for a single payment.



Content



U.S. Export Controls

EU Export Controls

UK Export Controls


Sanctions Updates

EU Sanctions

UK Sanctions

U.S. Sanctions




Unlock all exclusive posts and make sure you stay fully up-to-date. Access Our NEW FAQ to answer all your questions: https://www.customsmanager.info/plans-pricing


Start Next Friday: Weekly Wrap Up

Are you aware of the latest changes in customs and export controls? Join us for our new weekly online call, where you can stay ahead of the game. After the call, we offer an exclusive learning opportunity that covers crucial customs and global trade subjects in our weekly Lunch and Learn. Don't let this opportunity pass you by - registration is now OPEN!

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Lunch n' Learn



As a paid subscriber, you can access an exclusive 30-minute "Lunch 'n Learn" session every week for free, saving you 50 GBP (regular price for non-premium paid plan subscribers). This is a live training session regarding customs and/or export controls/sanctions and the agenda can be determined by the audience (but we do propose an agenda below). During this session, we will explore a specific topic in more depth every week. Find out more

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Due Diligence & AML


EBA issues AML guidance on crypto

The European Banking Authority (EBA) has extended its anti-money laundering and terrorist financing requirements to cover crypto firms, effective on December 30. The EBA aims to harmonize the approach crypto asset service providers (CASP) across the EU should adopt to combat financial crime. The new guidelines also include guidance for other credit and financial institutions exposed to crypto assets. Access here


Clyde & Co fines

International law firm Clyde & Co has been fined £500,000 by the Solicitor's Disciplinary Tribunal (SDT) for failing to conduct due diligence on a client required under anti-money laundering (AML) rules. Former partner Edward Henry Mills-Webb was also fined £11,900. The firm admitted to contributing to the failure and ordered the firm to pay costs totalling £128,197. The SRA's chief executive called the fine a wake-up call for firms not meeting their responsibilities.

Export Controls Updates

To make sure you never miss an export control update, bookmark https://www.customsmanager.info/all-news/categories/export-controls


⇒ EU Export Controls


No updates noted.


⇒ UK Export Controls


UK Export Controls: Export Licencing for dual use and military items - Explainer Video

Watch this video introducing export controls in the UK and why it matters


⇒ U.S Export Controls


Increased Penalties for Export, and Other Violations

The civil monetary penalty amounts that may be imposed for the following regulatory infractions after January 15, including those in which the related violation happened earlier, are being increased by the Department of Commerce to account for inflation.

According to the DOC, the precise fine imposed for a certain infraction will depend on several factors, such as:

  • Violations of 50 USC 1705(b) of the International Emergency Economic Powers Act; the maximum was raised from $356,579 to $368,136.

  • Breaches of 50 USC 4819, the Export Controls Act of 2018; the maximum amount was raised from $353,534 to $364,992.

  • Failure to provide export data or reports within the time frame specified by 13 USC 304; Maximum delinquent per day raised from $1,643 to $1,696; Maximum violation per day increased from $16,438 to $16,971

  • Other illegal export information operations as defined by 13 USC 305(b) with a $16,971 maximum instead of $16,438.

  • - Violations of foreign trade zones (19 USC 81s): the maximum amount was raised from $3,446 to $3,558.

  • Breaches of the Lacey Act (16 USC 3373(a)(1) and (a)(2)) pertaining to the import or export of wildlife; the maximums were raised from $31,908 to $32,942 and from $797 to $823, respectively.

  • Breaches of the High Seas Fishing Compliance Act (16 USC 5507(a)) pertaining to the import or export of seafood; the maximum amount was raised from $193,890 to $200,174.

  • Failing to provide any data needed under 22 USC Chapter 46 (foreign trade and investment in services survey) – the minimum was raised to $5,761 from $5,580, and the maximum was raised to $57,617 from $55,508

  • Violating the Fastener Quality Act (15 USC 5408(b)(1)): the maximum amount has been raised from $55,508 to $57,617.

  • The Chemical Weapons Convention Implementation Act (22 USC 6761(a)(1)(A) and (B)) prohibits certain conduct related to inspections and recordkeeping breaches; the maximum amounts have raised from $45,429 to $46,901 and from $9,086 to $9,380, respectively.


⇒ China Export Controls



China's Ministry of Commerce has accused the US of weaponizing and using export controls as a tool.

The ministry criticized the US for direct intervention in high-tech exports by Dutch companies to China, stating that the US has instrumentalized and weaponized export control issues. The Dutch government restricted ASML from exporting some lithography products to China, following US export controls aimed at limiting the Chinese military's access to high-end semiconductor technology. China firmly opposes such moves and will take necessary measures to protect its business interests. Read the article


Sanctions Updates

The EU, UK and US implement extensive sanctions laws. These rules provide processes for producing lists of individuals and businesses subject to asset freeze targets and financial and investment restrictions. Businesses must stay up to date with the latest sanctions rules to avoid accidental non-compliance. Read the collection of all articles we have written on this topic here https://www.customsmanager.info/all-news/categories/sanctions


⇒ EU Sanctions Updates


EU adds an individual to its autonomous sanctions list against ISIL(Da'esh) and Al-Qaida


The EU decided to add one individual to the list of those subject to restrictive measures against ISIL (Da'esh) and Al-Qaeda and persons, groups, undertakings and entities associated with them. The measures target Ahmed Khaled Müller, a member of Al-Shabab in Somalia. The sanctioned individual has participated in combat operations and committed terrorist acts on behalf of Al-Shabab. The latter operates in the Horn of Africa region, is responsible for numerous terrorist acts in Kenya, Somalia, as well as neighbouring countries, and is affiliated with Al-Qaida. Details


EU terrorist list: Council lists one individual in response to the 7 October attacks in Israel

The Council decided today to add one individual to the EU terrorist list. This decision comes as part of European Union’s response to the threat posed by Hamas and its brutal and indiscriminate terrorist attacks in Israel on 7 October 2023. Details


Guatemala: EU establishes dedicated framework of restrictive measures in support of democracy

EU Sanctions Against Russia: Content of the 12th Sanctions Package

The 12th round of sanctions against Russia has been adopted by the EU. It applies since 1 January 2024. This package aims to address loopholes, fight sanctions circumvention, and impose more import and export limitations on Russia. Details


Haitit Sanctions Regime

By UN sanctions on persons from Haiti, the EU amends Decision (CFSP) 2022/2319 on January 15, 2024. The UN added the four Haitian gang leaders listed below to its list of sanctioned individuals on December 8, 2023

  • Andre Johnson (Group ID: 16325)

  • Renel Destina (16326 Group ID)

  • Innocent Vitelhomme (Group ID: 16328)

  • Joseph Wilson (Group ID: 16327)

The EU modified Decision (CFSP) 2022/2319 on Friday, January 12, 2204, adding these 4 people.


⇒ UK Sanctions Updates


The UK's Consolidated Sanctions' List

Access the latest version of the UK consolidated sanctions list now. Date of last update 16.01.2023. Access here


UK Financial sanctions targets by regime

Exploring the Latest UK Financial Sanctions Targets Across Different Regimes. Full List of all Regimes


Isil (Da'esh) and Al-Qaeda sanctions regime designation

UK Government has made 4 administrative amendments to the following entries under the Isil (Da'esh) and Al-Qaeda sanctions regime. These individuals remain subject to an asset freeze, arms embargo and travel ban:

Tayeb Nail (Unique ID: AQD0326)

Saifi Ammar (Unique ID: AQ D0303)

Said Arif (Unique ID: AQD0299)

Habib Ben Ahmed Al-Loubiri (Unique ID: AQD0181)


Advice on the Sanctions of Guernsey

The Guernsey Financial Services Commission has published the following rules on its websites regarding sanctions, financing of terrorism, and financing of proliferation:


Bosnia and Herzegovina sanctions regime designation

The UK designated one entity under the Bosnia and Herzegovina sanctions regime, for their involvement in celebrations of Republika Srspka Day in direct contravention of the country’s constitution and court rulings.Mania D.O.O (Unique ID: BIH0004) is now subject to an asset freeze. Details here


⇒ U.S. Sanctions Updates


US penalties Financial intermediaries from Houthi

On Friday, January 12, 2024, OFAC sanctioned two companies, Global Tech Marine Services in the United Arab Emirates and Cielo Maritime in Hong Kong, for the transportation of Iranian goods on behalf of Sa'id al-Jamal, the Houthi financial facilitator backed by the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) network. Since March, OFAC has not targeted any boats with ties to Iran until now. Details here. The Department of the Treasury action was taken pursuant to Executive Order 13224, as amended. For more information on this designation, see Treasury’s press release.


US designations after the January 12, 2024, delivery of DPRK weapons to Russia

The US Department of State banned three Russian companies, one individual, and four planes in relation to the delivery and testing of DPRK ballistic missiles for use by Russia against Ukraine (notice, notice):

The Joint Stock Company, State Airlines' 224th Flight Unit, and Vladimir Vladimirovich Mikheychik, the company's general director, are the entities in dispute. The Vladimirovka Advanced Weapons and Research Complex is a Russian military facility used for missile testing; the Astaluk Firing Range is a Russian missile testing range; the company provides commercial air cargo transport services; and four aircraft are part of the US-designated Command of the Military Transport Aviation, which is suspected of being involved in the transfer of DPRK missiles.


DOJ Charges Two Political Consultants With FARA Violation

The DOJ began 2024 with a huge FARA enforcement statement. Two experienced political consultants with significant Washington links, Barry Bennett and Douglas Watts, agreed into a Deferred Prosecution Agreement (DPA) with DOJ last week in response to claims that they violated FARA for foreign government lobbying. Detail



Upcoming Export Control and Sanctions Training


Learn the essentials of dual-use products and export limits to avoid expensive fines. Our training will be advantageous to any US and non-US firm engaging in international trade, especially concerning items of US origin. Our training help prevent expensive export control and sanctions fines. It imparts essential knowledge that personnel responsible for export controls and sanctions compliance need to grasp.


Sanctions

This course develops the competencies that professionals need to deal with all key compliance aspects of sanctions laws and policies. Using examples from the EU, the UK and the U.S., we will explore how to check entities, individuals and organisations against sanctions lists, how to set up an effective restricted party screening programme, how to identify economic trade sanctions and how your products may be affected by it. We will determine due diligence requirements, and how you can identify attempts for circumvention. We will discuss how to apply for a sanction’s exemption licence, a licence exception / general licence. Includes a discussion around red flags and how to set up a sanctions policy and programme. Special feature: Participants will workshop through real sanctions’ case studies and explain the action that they would take to ensure compliance.


Dates (Click To Book)


Export Controls

This course develops the competencies that professionals need to deal with the four fundamental aspects of export controls: Product, Destination, End-User and End-Use Controls. Using examples from the EU, the UK and the U.S., we will explore how to determine if an item is subject to export controls and detail the steps to acquire an export control licence and/to apply for a licence exception / general licence. Includes a discussion around red flags and Internal Export Compliance Programmes (ICP/ECP). Special feature: A hands-on workshop where you get to determine the export control rating of your product by yourself (supported by your expert instructor).


Dates (Click To Book)


U.S. Export Controls

This course focuses on U.S. Export Controls, the EAR and ITAR.  Discover how an item can be subject to the EAR or ITAR, how to verify items against the CCL or the USML, how to determine licence requirements and licence exceptions, how to make a licence application, check Export Controls specific restrictive lists and more. We cover

  • The enforcement authority of the Bureau of Industry and Security (BIS) extends overseas.

  • Key US law on export restrictions and importance for non-US firms.

  • Concepts and definitions related to dual-use products.

  • the many categories of EAR bans for non-US companies.

  • The many export classifications and categories, including dual use.

  • The Commerce Control List: An Introduction (CCL).

  • the primary dangers associated with doing business with US companies.

  • Fines and penalties.

  • Vigilance and warning signs.

  • How to create an export compliance programme (ECP) that works?

  • How BIS licences are applied for.


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Special feature: A close look at the extraterritorial application of U.S. Export Controls – De Minimis, Foreign Direct Product Rule, Second Incorporation Principle and more

Dates (Click To Book)



What if I have a question regarding these updates


We invite you to use the chat function available on www.customsmanager.org to ask any questions related to this update. Our skilled team of export control and sanctions managers will be happy to provide you with the information you need within 24 hours.

Sources


EU

  • Official Journal of the EU

  • DG TRADE Website

  • Social Media (LinkedIn, Twitter, etc).

  • Information on the National Export Control & Sanctions Website of Member States


U.S.

  • Bureau of Industry and Security (BIS)

  • Department of Commerce

  • Office of Foreign Asset Control (OFAC)

  • Social Media (LinkedIn, Twitter, etc).


UK

  • Information on gov.uk

  • Information on legislation.gov.uk

  • Department of Business and Trade

  • Social Media (LinkedIn, Twitter, etc).


Other

  • United Nations (Sanctions)

  • Social Media (LinkedIn, Twitter, etc).



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