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Part II: Sanctions Enforcement Actions
January 12, 2023 |White Paper

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.

Topics:OFAC Sanctions Activity, OFAC, SDN List, Iran Export Controls
US Issues More Russia Sanctions, Adds to Entity List
June 29, 2022 by Ian Cohen and Ben Perkins|Top News

The U.S. this week announced a host of new sanctions targeting Russia’s defense industrial base, including export restrictions against entities helping Moscow evade U.S. export controls and new financial sanctions targeting state-owned companies. The sanctions target more than 100 entities and 50 people supporting Russia’s defense industry and add 36 entities to the Commerce Department’s Entity List, including six for supporting Russia’s military.

Topics:OFAC, Export Administration Regulations, Commerce Control List, Export Control Classification Number (ECCN), Iran Export Controls
BIS Needs Better Enforcement of FDP Rule to Protect US Tech, Senate Republicans Say
November 17, 2021 by Ian Cohen|Top News

The Bureau of Industry and Security needs to better enforce its foreign direct product (FDP) rule, which is not adequately stopping Huawei and other Chinese companies from acquiring certain sensitive U.S.-produced technology, eight Republican senators said in a Nov. 15 letter to Commerce Secretary Gina Raimondo. The senators said Commerce’s “lax enforcement” of the rule has encouraged other technology firms to sell to companies on the Entity List, said the lawmakers, who all serve on the Senate Committee on Commerce, Science and Transportation.

Commerce's Plans to Further Restrict Foreign Sales to Huawei Could Have 'Dramatic' Implications, Former Commerce Official Says
December 16, 2019 by Ian Cohen|Top News

BOSTON -- If the Commerce Department follows through on plans to expand the limits of the Export Administration Regulations to further control foreign shipments to Huawei, it will have a “dramatic” impact on international supply chains, said Kevin Wolf, a trade lawyer with Akin Gump and Commerce’s former assistant secretary for export administration. The measures, which Commerce confirmed it was considering earlier this month (see 1912100033), include expanding the Direct Product Rule and broadening the de minimis rule to make more foreign-made goods subject to the EAR.