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The Export Controls & Sanction Manager - Edition 4

Edition 4 - 2024 - Week 3 of your blog-style magazine on export controls & sanctions.

The period covered 23.01 - 31.01.2024.



A word from the editor


A lot has happened in EU, UK and U.S. Export Control & Sanctions last week. We start with the UK where important guidelines for sanctions compliance to sanctions advisory were published, along with the "usual" designations - often coordinated with the U.S.


Staying on sanctions, the EU renewed its Russia sanctions for another six months and made several designations within its Iran, Sudan, and Syria sanctions regimes. Find out who made it on the list and ensure you are screening against the individuals.


The focus, however, last week was on the export control initiatives of the EU and U.S. Although already published in December, the new House Report on strengthening U.S. Export Controls following Chinese influence is particularly noteworthy. So is the new economic security initiative of the European Union, which includes a White Paper on Export Controls that you can download here.


As usual, we hope that this update saves you time having to research all of this information yourself and going through endless newsletters, update emails, social media postings and official gazettes, federal registers, official journals and the like. If we take many hours consolidating all the updates of last week that any export and sanctions professional needs to know about, there is no need for you to do the same. We've got you covered.


Instead, replace hours of research with 15 minutes on this blog entry. And do something much more productive instead - like enjoying time with your loved ones. Your' welcome!


Finally, may I invite you to our free webinar on the 23rd of February 2024 on EU & UK Sanctions against Russia - on the day before the dreadful invasion began, two years ago. Its free. See below.


Have a captivating lecture! Any questions? Any feedback? Please don't hesitate to reach out to us at info@customsmanager.org via email.


See you live online, Friday.


Arne



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

FREE WEBINAR - Two Years Of War In Europe: EU and UK Sanctions Against Russia in FOCUS




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


UK anti-money laundering and terrorist financing legislation redefine high-risk third nations

The UK Government redefined high-risk third countries on January 22, 2024, under the Money Laundering and Terrorist Financing (High-Risk Countries) (Amendment) Regulations 2024. The modified definition—a country on FATF's High-Risk Jurisdictions subject to a Call for Sanction or Increased Monitoring—will speed up UK FATF list updates. Details here.

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


Understanding the EU's White Paper on Export Control: Key Takeaways and Implications


The EU has published a new White Paper on Export Controls, which highlights the need to fully implement the EU’s dual-use regulation and makes several recommendations for consistent controls throughout the EU. The EU's White Paper on Export Controls proposes short and medium-term actions to improve coordination of export controls on dual-use goods, such as advanced electronics, toxins, nuclear or missile technology. The Commission proposes uniform EU controls on items not adopted by multilateral regimes, and a senior-level forum for political coordination. The evaluation of the EU Dual-Use Regulation is advanced to 2025.


New EU Export Control Reporting Guidelines

The European Commission has issued new guidelines for data gathering and processing on export controls, following a White Paper on the regulation. The guidelines aim to increase transparency and transparency in Member States' licensing decisions, facilitating dialogues and exchanges with third countries and promoting good reporting practices. Find out more and download the new guidance.


EU: Will the Commission's New Initiatives Truly Strengthen Economic Security?

The European Commission has adopted five initiatives to strengthen the EU's economic security amid geopolitical tensions and technological shifts. The package aims to enhance economic security while maintaining openness to trade, investment, and research. What Are the Five Initiatives Adopted by the EU Commission to Strengthen Economic Security Amidst Geopolitical Tensions? Our summary and analysis


⇒ UK Export Controls


No Update Noted (What does this mean?)


⇒ U.S Export Controls


Revamping US Export Control Regulations: Our Summary


Revamping US Export Controls for China: Key Takeaways from the House Foreign Affairs Committee Report


“We can no longer afford to avoid the truth: the unimpeded transfer of U.S. technology to China is one of the single-largest contributors to China’s emergence as one of the world’s premier scientific and technological powers,” stated Chairman McCaul. “Now is the time to fix this – and the stakes couldn’t be higher. The United States must have a win-at-all-costs mentality in these emerging technologies and invest in innovation while denying and delaying China’s access to critical U.S. technologies.” Read Report here


What Are Semiconductor Users Saying About Mature Node Semiconductors? A Survey Evaluation

 How Does the Use of Mature-Node Semiconductor Devices Affect Critical Infrastructure and National Security in the U.S.? Take part in this survey


Sanctions Updates

We highlight the most important developments in the realm of EU, UK and U.S sanctions in our weekly report. Please do not hesitate to get in touch with any member of our Sanctions team mentioned above if you need any clarification about any of the developments listed below. For the collection of all articles we have written on this topic here https://www.customsmanager.info/all-news/categories/sanctions


⇒ EU Sanctions Updates


EU renews Russia sanctions

The EU has extended its sectoral sanctions on Russia by an additional six months, expiring on July 31, 2024. Details here


EU makes human rights designations

Under its human rights sanctions system, the EU has named 4 persons and 1 entity Valentina Levashova, Ludmila Smolkina, and Oleg Alypov, two judges and a prosecutor involved in Vladimir Kara-Murza's arrest and incarceration; The Safe online League and its Chairwoman, Ekaterina Mizulina, are accused of censoring online content producers. Details here


Arrests of three Dutch citizens for circumventing Russian sanctions

Incidents involving investigations were documented in Canada, Estonia, Latvia, and Germany.

Three individuals were apprehended in the Netherlands this month as a result of a worldwide inquiry into a global contraband network that managed to circumvent EU sanctions against Russia. Last week saw the apprehension of three fifty-year-olds from Diemen and The Hague by the Fiscal Information and Investigation Service. The apprehensions took place on January 9, subsequent to operations that were conducted in Canada, Estonia, Latvia, and Germany.

The investigation was coordinated by Eurojust, which asserted that two of the suspects were administrators of a Dutch company that transported "technological and laboratory equipment" to Russia in 2017 for potential "military purposes." After Russia's full-scale invasion of Ukraine in 2022, the EU imposed waves of sanctions; however, the restrictions have been criticised for having an excessive number of loopholes. A Dutch court sentenced a Russian merchant to eighteen months in prison in October of last year for exporting electronics to Russia while referring to sanctions evasion as his "revenue model." Press release


Sudan: Council adds six entities to EU sanctions list

The Council today adopted restrictive measures against six entities, in view of the gravity of the situation in Sudan, where fighting is ongoing between the Sudanese Armed Forces (SAF) and the Rapid Support Forces (RSF) and their respective affiliated militias.

The new listings – the first within the Sudan regime - include six entities responsible for supporting activities undermining the stability and political transition of Sudan.

Among the entities listed are two companies involved in the manufacture of weapons and vehicles for the SAF (Defense Industries System and SMT Engineering); the SAF-controlled Zadna International Company for Investment Limited and three companies involved in procuring military equipment for the RSF (Al Junaid Multi Activities Co Ltd, Tradive General Trading and GSK Advance Company Ltd). Details and legal texts


Syria Sanctions Updates

The European Council has approved additional restrictive measures against six individuals and five entities due to the ongoing Syrian conflict. The sanctions include asset freezes, prohibition of funds or resources, and travel bans for listed individuals. The Council remains concerned about the ongoing conflict and the Syrian regime's repression. It emphasizes the need to maintain and develop the effectiveness of the measures and reiterates that the only path to sustainable peace for Syria is a political solution in line with United Nations Security Council Resolution 2254.


⇒ UK Sanctions Updates


UK: Mastering Sanctions Compliance: A Comprehensive Guide for Sanctions Advisors

Navigating Legal and Regulatory Obligations: A Guide for Firms. On January 23, 2024, the UK announced sanctions risk assessment recommendations for advisors. The guide helps companies evaluate their exposure to UK sanctions regime risks by identifying who is at risk of sanctions violations, why a firm-wide risk assessment is vital, what a sanctions risk assessment should look like, and how to perform one. Download the recommendation here.


Iran sanctions Updated

The UK has appointed 1 company and 7 persons to “tackle the domestic threat posed by the Iranian regime” OFSI and OFAC said Naji Ibrahim Sharifi-Zindashti heads an international narcotics and trafficking network that assassinates and kidnaps Iranian government officials;

IRGC-QF Unit 840 and officers, Mohammed Ansari and Muhammed Abd al-Razek Kanafani, were linked to a conspiracy to kill two Iranian International TV broadcasters in the UK, according to an ITV news report. Abdulvahap Kocak, Ali Kocak, Ali Esfanjani, and Muhammad Reza Naserzadeh, two Turkish and two Iranian nationals, killed an Iranian dissident in Istanbul.


OFSI is conducting an information session on oil price limit updates tomorrow

Tomorrow (Thursday) at 10:30 a.m., OFSI will convene industry teach-ins to discuss the modifications to the oil price limit guidance. Write to register for one of these online sessions. OilPriceCap.OFSI@hmtreasury.gov.uk


UK adds Russian cyber hacker to cyber regime

On January 23, 2024, the UK, Australia, and the US identified a Russian cyber hacker under the Cyber (Sanctions) (EU Exit) Regulations 2020 Regime for the Medibank intrusion and medical data release. Aleksandr Gennadievich Ermakov has travel and asset freezes. Details here.


UK sanctioned four under Yemen regime

On January 25, 2024, the UK sanctioned 4 people for Red Sea marine disruption under the Yemen Sanctions Regime. An asset freeze, targeted weapons ban, and travel restriction apply to Mohamed Nasser Al-Atifi, Muhammad Ahmad al-Talibi, Muhammad Ali Al-Qadari, and Muhammad Fadl Abd Al-Nabi. Details here.



The UK government sanctioned six Hamas-affiliated parties

The UK Government added sanctions against six Hamas and Palestinian Islamic Jihad (PIJ) groups on January 22, 2024, with the US and Australia.Zuheir Shamlakh, Ahmed Sharif Abdallah Odeh, Ismail Barhoum, Hassan Al-Wardian, Jamil Yusuf Ahmad Aliyan, and Al Mutahadun for Exchange participated. Details here.


A sanctions' evasion in the UK art storage business

A notification by UK gov on 23 January 2024 warned of sanctions evasion in the UK art storage business. The notice discusses how criminals use the art market to conduct crimes and includes critical signs and questions regarding client conditions, such as efforts to transfer artwork to an intermediary and sell it rapidly or relocate it to another country. The notice includes many case examples illustrating these issues. Details here.


Hizb ut-Tahrir

Hizb ut-Tahrir was declared a terrorist organisation by the UK government on January 19, 2024, after Parliament approved a draft order on January 15. Hizb ut-Tahrir membership, support, and expression are illegal under this edict. An offence may result in a 14-year prison term or fine.  Details here.



⇒ U.S. Sanctions Updates


US designates Iran after assassination plots

11 people have been identified by the US for listing on the US sanctions list for plotting to kill Iranian dissidents and opposition activists.Naji Ibrahim Sharifi-Zindashti, Abdulvahap Kocak, Ali Kocak, Ali Esfanjani, and Muhammad Reza Naserzadeh (also UK-designated); Associates of Naji Ibrahim Sharifi-Zindashti include Reza Hamidiravari, Nihat Abdul Kadir Asan, Ekrem Abdulkerym Oztunc, and Shahram Ali Reza Tamarzadeh Zavieh Jakki. Damion Patrick John Ryan and Adam Richard Pearson, Canadian Hells Angels Outlaw Motorcycle Group members, were allegedly recruited by Zindashti's network to assassinate US refugees from Iran. They are also charged with conspiracy to use interstate commerce in a murder-for-hire plot.


OFAC names an Iraqi bank owner for Iran supply.

OFAC has blacklisted Hamad al-Moussawi, the owner and chairman of Al-Huda Bank in Iraq, for suspected IRGC-QF support, including funding proxy militias like Kata'ib Hizballah (notice).

According to the US Treasury, Al-Huda Bank is a foreign financial institution of major concern for money laundering. FinCEN advocated banning domestic financial institutions and agencies from establishing or maintaining a correspondent account for Al-Huda Bank to further isolate the bank from the US financial system. Details here


US evaluates Venezuela sanctions following Supreme Court ruling and GL expiration.

The US is revisiting its decision to provide Venezuela some sanctions relief in reaction to the Venezuelan Supreme Court ruling banning opposition presidential candidate Maria Corina Machado. OFAC notified yesterday that the general licence permitting companies to interact with Venezuelan state-owned gold mining business Minerven would expire on 13 February 2024 (previously open-ended). The US general licence for PdVSA transactions expires in April 2024. Details here




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

  • Social Media Postings


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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