top of page
Search

The Export Controls & Sanction Manager - Edition 7-24

Edition 7 - 2024 - Week 8 of your blog-style magazine on export controls & sanctions.

The period we covered was 14.02.2024 - 21.02.02.2024 with live links




Executive Summary


Leaders from the US, UK and the UE have expressed outrage by the death of the Russian opposition politician Alexei Navalny, which may lead to further sanctions against Russia following the grim second anniversary of the Russian invasion of Ukraine. We are running a free Webinar "Two Years Of War In Europe: EU and UK Sanctions Against Russia in FOCUS" which will take place on Friday, and you are welcome to join on www.customsmanager.org/events.


This week we cover the latest updates on export controls from the EU,U.S. or the UK and sanctions, AML and Due Diligence legislation, too. For example, we cover the "Russian sanctions loophole" in the Baltics or ask is PWC has been helping businesses circumvent EU sanctions against Russia.


For a weekly wrap up of all the changes in these editions, join our Weekly Wrap Up, our live community meet every Friday at 12pm. Register to take part here for free. This is followed by a "Lunch N Learn" and you can register here. The focus is on "Sanctions - U.S. and EU".

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



Due Diligence & AML


No update noted.



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 Update Noted (What does this mean?)



⇒ UK Export Controls


No Update Noted (What does this mean?)



⇒ U.S Export Controls


US BIS and goods forwarder reach a settlement agreement over the goods forwarder's breach of Iran export regulations on February 14, 2024.

US BIS and the goods forwarder reached a settlement agreement over the export control breaches pertaining to Iran. A settlement agreement has been struck in response to the US Bureau of Industry and Security's discovery that Cargosave, a US-based goods forwarder, enabled the shipment of corporate servers and switches from the US to Iran without the necessary licence. Cargosave's export permits are suspended for two years, with the possibility of revocation if the company violates export controls during this time. Additionally, workers of Cargosave must complete KYC and compliance training. No punishment was imposed. Update here

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: Sanction exception - humanitarian action

By adding a humanitarian exemption to the asset freeze measures for a first 12-month period, the Council today resolved to alter the EU framework on restrictive measures to combat terrorism. Because of the decision, specific groups of humanitarian actors—such as those mentioned in UN Security Council resolution 2664 (2022)—as well as organisations and agencies recognised as humanitarian partners of the European Union or its member states, as well as specialised agencies of member states—may conduct business with the individuals and entities on the list without first obtaining permission, provided that the transaction is for the purpose of providing humanitarian assistance or assisting with other initiatives that meet the basic human needs of those in need. Please refer here for more information.


The Baltic border loophole in EU's Russia sanctions

Customs officials in EU frontline states, including Estonia, Latvia, and Lithuania, are aware that truckers are shipping banned goods into Russia, but they can't do much about it, Politico has reported. The Baltic border crossings have become a prime destination for those seeking to evade sanctions on goods with civilian and military uses, as well as luxury items like cars. With limited resources, it's often impossible for those responsible to know what should be waved through and what shouldn't. Acording to Politico, Lithuania's foreign ministry reports that only 6% of goods crossing into Belarus or Russia from Lithuania originate from within the country. Some 6,000 customs codes fall under sectoral sanctions for Russia and Belarus. Not everything crossing the Baltic borders is declared as headed for Russia, and not everything is declared as headed for Belarus. Cross-country traffic, including goods declared to be headed across Russia to countries like Kazakhstan and Kyrgyzstan, has seen a surge of imports since sanctions were imposed on Russia. Many sanctioned goods that are supposed to transit Russia are simply unloaded once they cross the border and then disappear. Customs officials estimate that less than half the goods they inquired about were cleared for customs in the countries of destination. An analysis of European Commission data found that the EU had registered exports of €1.87 billion in critical products like fuel, machinery, and vehicle parts to Kazakhstan in 2022, while Kazakhstan declared only around €1.1 billion in such products coming in.


Is PwC helping to break EU sanctions?

Three parties' worth of MEPs in the European Parliament have asked the EU Commission to respond to press reports and leaks that suggest the international consulting firm PwC's Cyprus branch helped a Russian national who was subject to EU sanctions transfer over a billion euros' worth of assets to get around the sanctions. If this is accurate, it is a grave concern that should, undoubtedly, have immediate and substantial repercussions for PwC's relationship with any EU institutions, including a prohibition from using EU property.

In light of these grave accusations, MEPS requested that the Commission respond to the following three inquiries (and provide a justification for its response):

  1. Will the Commission immediately halt all current and upcoming agreements with PwC and maintain that suspension while it conducts its investigation?

  2. Will the Commission take action to exclude PwC from any current or future contracts with the EU, directly or indirectly, if it turns out that a PwC branch has actively assisted one or more Russian citizens in avoiding EU sanctions and asset-freezing?

  3. Can the Commission clarify what other actions, beyond from criminal prosecution, may be taken against PwC for its assistance in evading EU sanctions?

The EU Commission has now responded. Here is the answer



⇒ UK Sanctions Updates


Update to Russia Guidance

The Office of Financial Sanctions Implementation (OFSI) in the UK is responsible for implementing and enforcing financial sanctions, including the Russia (Sanctions) (EU Exit) Regulations 2019.

These regulations cover the UK and apply to conduct by UK persons outside the UK. They include asset freezes, restrictions on access to capital markets, loans, credit arrangements, clearing services, dealing in reserves for Russian state-owned financial institutions, investments in Russia and non-government controlled Ukrainian territory, trust services, and investments in relation to Crimea and Sevastopol. The regulations also establish penalties and offences to enforce these sanctions. UK individuals or entities are prohibited from dealing with transferable security or money-market instruments issued after 0:01am on 1 March 2022, and from establishing correspondent banking relationships with entities such as Sberbank, VTB Bank, Gazprombank, Vnesheconombank (VEB), Rosselkhozbank, OPK Oboronprom, United Aircraft Corporation, Uralvagonzavod, Rosneft, Transneft, and Gazprom Neft. On 20 February 2024, OFSI updated its Russia guidance to add FAQ number 56, explaining when persons are required to report to OFSI under regulation 70A (5).


Download the entire guidance here:




OFSI has amended Insurance General Licence

The wording in permissions 5.1 and 6.6 has been clarified, and frozen UK bank accounts have been removed from permissions 4.1, 4.3.1, and 6.1 to make it clear that DP payments are not limited to those made from frozen money. 


OFSI has issued a new GL, on Oil Price Cap focusing on Russia.

INT/2024/4423849. This replaced the previous General Licence Oil Price Cap INT/2022/2469656, which expired on 18 February 2024. As long as the price paid for Russian oil or oil products is at or below the price cap, this new general licence allows the supply or delivery of Russian crude oil and oil products by ship, as well as the provision of related services. Please review the GL Publication Notice.


OFSI Introduction to Financial Sanctions Licensing Webinar

A free webinar on sanctions licencing is being held by OFSI on Thursday, February 29, 2024, at 10 a.m. Improve your understanding of financial sanctions licensing with this free webinar from the Office of Financial Sanctions Implementation. Our licensing specialists will cover:

  • General and specific licensing

  • Applying for a licence amendment

  • Returning applications without action

  • Top tips for licence applications

This webinar will be available to watch on demand from GOV.UK Sign up here.

 


OFSI Russian Oil Service ban

The thirty-day period has been shortened to twenty-eight days for the provision of additional attestations or itemised supplementary expenditures. It has been made clear that the obligation to stop doing business with entities who refuse or are unable to disclose information is particular to the terms of the contract and only applies to policies pertaining to the seaborne transportation of Russian oil and oil products. The attestation approach has been modified by the G7+ Oil Price Cap Coalition in order to improve compliance and narrow potential avenues for circumvention.  Members of the Coalition have released updated recommendations regarding the Oil Price Cap as part of our strong emphasis on heightened compliance. Significant alterations to the attestation procedure, such as the need for itemised supplementary cost information upon request and per-voyage attestations, would enhance openness and thwart Russian attempts to evade the measure. For more information please refer here. Please study this in conjunction with the new OFSI GL INT/2024/4423849. 

 


⇒ U.S. Sanctions Updates


United States Sanctions Affiliates of Russia-Based LockBit Ransomware Group

The United States has designating two individuals who are affiliates of the Russia-based ransomware group LockBit. This action is the first in an ongoing collaborative effort with the U.S. Department of Justice, Federal Bureau of Investigation, and our international partners targeting LockBit.


Humanitarian-Related Assistance and Critical Commodities to the Yemeni People

OFAC issuing an OFAC Compliance Communiqué: Guidance for the Provision of Humanitarian-Related Assistance and Critical Commodities to the Yemeni People in response to questions from the NGO community and the general public on how to ensure humanitarian assistance and trade continue to flow to the Yemeni people while complying with OFAC sanctions. More here


New Counter Terrorism General License 28

OFAC has issued Counter Terrorism General License 28, "Authorizing Transactions for Third-Country Diplomatic and Consular Missions Involving Ansarallah." More here

 

Individuals from other Nationalities added to OFAC's SDN List

 

Regulatory Amendment to the North Korea Sanctions Regulations

The Office of Foreign Assets Control (OFAC) of the Department of Treasury has made changes to the North Korea Sanctions Regulations in order to add or modify general licences that will allow for the facilitation of specific journalistic and humanitarian endeavours.  In particular, OFAC has added general licences to authorise certain transactions pertaining to the export and reexport of goods approved by the U.S. Department of Commerce; the provision of specific agricultural commodities, medications, and medical devices; and specific journalistic activities in North Korea. It has also amended an existing general licence for nongovernmental organisations.  Please refer here for the published regulation.



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.


​

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).



About Customs Manager’s Customs & Global Trade Intelligence Services

The Premium Professional Legislative Monitoring Service (PLM) is a research and curation service which checks for legislative updates from official government websites based on the selected jurisdictions and topics. Paid Plan subscribers can access regular law change notifications to ensure they never miss a significant legal change on www.customsmanager.info – a website dedicated to customs & trade intelligence. At the same time, they save valuable time by engaging our dedicated trade specialists to carry the monitoring out for them. Premium subscribers also unlock all content on the Customs Manager’s Ltd. website, including our Customs & Trade Blog on www.customsmanager.info , providing vital thought leadership development services to empower them to trade effectively, efficiently and, of course, compliantly, across borders. Premium Subscribers can add jurisdictions and topics for an additional charge.


About Customs Manager Ltd.

We aim to empower people with import, export and transport responsibilities with helpful advice, insightful training and relevant trade intelligence services. We devote all our passion and energy to helping businesses grow faster cross-border. Working with us means having your own multilingual Customs Manager on standby to help you trade effectively, efficiently and, of course, compliantly wherever you want to go. Includes Brexit support and the ability to lodge customs declarations + Rules of Origin

Stay in Touch

· Twitter: @customsmanager


Important Notice

Customs Manager Ltd. owns the copyright in this document, except for external documents and links we refer to or make available.

You are not allowed to use this information in any way that infringes its intellectual property rights. You may have to hold a valid licence to use this information. A licence can be obtained by becoming a Paid Plan subscriber to the Customs Managers’ Customs & Trade Intelligence service, also known as Professional Legislative Monitoring (PLM). As a Paid Plan subscriber, you may download and print this information which you may then use, copy or reproduce for your internal non-profit-making purposes.

However, you are not permitted to use, copy or reproduce this information to profit or gain.

In addition, you must not sell or distribute this information to third parties, not members of your organisation, whether for monetary payment or otherwise.

This information is intended to serve as general guidance and not constitute legal advice. The application and impact of laws can vary widely based on the specific facts involved. This information should not be used as a substitute for consultation with professional legal or other competent advisers. Before making any decision or taking action, consult a Customs Manager Ltd. professional.

In no circumstances will Customs Manager Ltd be liable for any decision made or action taken in reliance on the information contained within this document or for any consequential, special or similar damages, even if advised of the possibility of such damages.



 
 
 

Comments

Terms of Website Use

Cookie policy

Privacy policy

© 2025 by Customs Manager Ltd.

bottom of page