The Office of Foreign Assets Control this month released new guidance to outline how people and companies should submit information, documents and “other materials” to the agency during a sanctions breach investigation, for voluntary disclosure, in response to an OFAC subpoena, and more. The guidance updates the agency’s “former data delivery standards,” OFAC said, and “provides technical and general guidance to persons submitting material to OFAC,” especially for submissions “that may entail voluminous documentation (e.g., more than 100 pages).” The document includes guidance for “organizing document productions,” includes “general conventions for submitting electronic documents,” and provides guidance on submitting data under and over 150 megabytes in total size.
The Financial Action Task Force recently updated its lists of jurisdictions with “deficiencies” in combating terrorism financing, weapons proliferation and other sanctions-related issues, the Financial Crimes Enforcement Network said last week. The FATF added Monaco and Venezuela to its list of Jurisdictions Under Increased Monitoring and removed Jamaica and Turkey from the list. The FATF’s list of High-Risk Jurisdictions Subject to a Call for Action remained the same and still lists Iran, North Korea and Myanmar.
House Speaker Mike Johnson, R-La., said July 8 that he hopes to have a "significant package of China-related legislation" signed into law this year, including measures to "punish" Chinese military firms that provide material support to Russia and Iran.
Charlotte Baskin-Gerwitz, a former Office of Foreign Assets Control sanctions compliance officer, has joined J.P. Morgan as its vice president of global sanctions advisory, she announced July 1 on LinkedIn. Baskin-Gerwitz, who left OFAC in 2023, most recently worked as an associate in Morrison Foerster’s national security practice.
Rep. Bill Huizenga, R-Mich., introduced a bill last week that could strengthen sanctions against several sources of funding for Myanmar's military.
The U.K. issued a general license July 3 allowing certain transactions involving sanctioned parties and visa application service providers. Under the license, providers can receive and remit visa application fees, and British individuals and businesses can make visa application payments on behalf of sanctioned parties. Details of those transactions must be reported to the U.K.'s Office of Financial Sanctions Implementation within 28 days of making the payment.
Italy on July 1 published a national export control list for goods that aren’t yet listed by the EU’s dual-use export control regulation but that the country is requiring to have a license for export, Italian trade consultant ZPC said in a client alert, according to an unofficial translation. The announcement follows similar moves by Spain, France and the Netherlands, ZPC said, adding that the lists are a way for European countries to coordinate on export restrictions that aren’t yet agreed to by all member states or at multilateral export control forums, such as the Wassenaar Arrangement. The European Commission began publishing a compilation of member states' national export control lists last year (see 2310270019).
Shipments of used vehicles aren’t subject to U.S. regulations governing those exports if the U.S. seller doesn’t transfer the vehicles’ titles, ownership and other responsibilities to the foreign customer until after the vehicle is delivered overseas, CBP said in a recent customs ruling.
The EU on July 3 declined to extend the protections in the Energy Charter Treaty -- a trade and investment deal for the energy sector -- to investments and investors from Russia and Belarus in order to boost its sanctions enforcement efforts, the European Commission announced. While neither Russia nor Belarus is a party to the Energy Charter Treaty, investors from these countries could theoretically use corporations set up in a signatory country to allege that the EU or its member states have violated "investment protection obligations" of the ECT and bring investor-state dispute settlement proceedings, the commission said. The EU's move eliminates the basis for making any such claim.
Douglas Robertson, former vice president of KanRus Trading Co., pleaded guilty on July 2 to conspiring to violate U.S. export laws by shipping "sophisticated and controlled avionics equipment to customers in Russia," DOJ announced.