A U.S. insurance company was fined about $170,000 for violating the Cuban Assets Control Regulations, the Treasury’s Office of Foreign Assets Control said in a Dec. 9 enforcement notice. Allianz Global Risks US Insurance Company (AGR US), a subsidiary of Germany-based Allianz SE, committed more than 6,000 violations of the CACR, OFAC said.
OFAC sanction activity
The Treasury’s Office of Foreign Assets Control sanctioned more than 40 people and entities involved in corruption networks in Europe, Asia and Latin America, and issued a general license to allow for wind-down activities, according to a Dec. 9 notice.
The Treasury’s Office of Foreign Assets Control issued two new Venezuela-related frequently asked questions concerning filing a lawsuit against sanctioned Venezuelan people or entities and conducting an auction for shares of a sanctioned Venezuelan entity, according to a Dec. 9 notice.
Chubb Limited, a Swiss holding company, was fined about $65,000 for more than 20,000 violations of the Cuban Assets Control Regulations, the Treasury's Office of Foreign Assets Control said in an enforcement notice. The violations were the responsibility of ACE Limited -- an insurance and reinsurance service provider with locations in Switzerland, U.S. and Britain -- which merged with Chubb Corp. in 2016 to form Chubb Limited.
A US telecommunications company may have violated U.S. sanctions against Sudan, according to the company’s Dec. 4 filing with the Securities and Exchange Commission. Comtech Telecommunications Corp. disclosed to the Treasury's Office of Foreign Assets Control in 2014 that it sent a “shipment of modems” to a Canadian customer, which was eventually “incorporated into a communication system” destined for an end-user at the Sudan Civil Aviation Authority, the filing said. OFAC subpoenaed Comtech in 2015 for information about the sale, the company said, which was worth about $288,000. Comtech responded to the subpoena and alerted OFAC of the company’s repair of three modems for a Lebanese customer who may have rerouted the modems from Lebanon to Sudan without the required U.S. license, the filing said. Comtech entered into two tolling agreements with OFAC, including one in November, which extends the statute of limitations in the case through June 2020.
The Treasury’s Office of Foreign Assets Control sanctioned three Iranian militia leaders for attacks on peaceful protests and an Iraqi millionaire for corruption, Treasury said in a Dec. 6 press release. The militia leaders, Qais al-Khazali, Laith al-Khazali and Husayn Falih ‘Aziz al-Lami, opened fire on protesters, killing dozens, Treasury said. Both Qais al-Khazali and Laith al-Khazali are leaders of Iran-backed Asa’ib Ahl al-Haq, a militia in Iraq. ‘Aziz al-Lami was tasked by senior militia commanders to suppress protests in Iraq and was a part of Iran’s Islamic Revolutionary Guard Corps-Qods Force. Khamis Farhan al-Khanjar al-Issawi, an Iraqi businessman, allegedly bribed government officials for “personal gain,” including by securing government contracts, Treasury said.
An Iranian businessman was sentenced to 46 months in prison for illegally exporting carbon fiber from the U.S. to Iran, the Justice Department said Nov. 14. Behzad Pourghannad worked with two others between 2008 and 2013 to export the carbon fiber to Iran from third countries using falsified documents and front companies, the agency said.
Apple was fined about $465,000 for violations of the Foreign Narcotics Kingpin Sanctions Regulations after it hosted, sold and “facilitated the transfer” of software applications and content belonging to a sanctioned company, the Treasury’s Office of Foreign Assets Control said in a Nov. 25 notice. Apple allegedly dealt in “the property and interests” of SIS d.o.o., a Slovenian software company added to OFAC’s Specially Designated Nationals List in 2015.
Export Compliance Daily is providing this recap of sanctions and export controls enforcement over the past year. Intended to assist export compliance professionals, lawyers and others in the export world stay up to date with current enforcement trends, this guide includes summaries of prominent enforcement actions by the Treasury's Office of Foreign Assets Controls, the Commerce Department's Bureau of Industry and Security, and the Justice Department since Export Compliance Daily began publishing in March 2019.
The Treasury’s Office of Foreign Assets Control sanctioned 17 people and seven entities, including Russia-based Evil Corp, for acting as “malicious cyber-enabled actors,” according to a Dec. 5 press release. Evil Corp is a “cybercriminal” organization responsible for the development of Dridex malware, which infects computers to harvest login credentials from “hundreds” of banks in more than 40 countries, leading to more than $100 million in theft, Treasury said. Evil Corp’s actions have caused “millions of dollars of damage” to U.S. and international financial institutions, including their customers, the press release said.