Export Compliance Daily is providing readers with some of the top stories for Nov. 25-29 in case you missed them.
OFAC sanction activity
The Treasury’s Office of Foreign Assets Control identified and sanctioned six ships belonging to Petroleos de Venezuela, Venezuela's sanctioned state-owned energy company, Treasury said in a Dec. 3 press release. The agency also identified the vessel Esperanza as blocked property of Caroil Transport Marine Ltd., which was sanctioned by OFAC in September. Esperanza was previously listed on OFAC’s Specially Designated Nationals List as “Nedas,” Treasury said.
A U.S. electronics and computer component company may have violated U.S. sanctions on Iran and Syria, the company said in a Nov. 7 filing with the Securities and Exchange Commission. Colorado-based Arrow Electronics said a “limited number of non-executive employees … facilitated product shipment” to customers for re-export to people covered by U.S. sanctions on Iran and Syria. The transactions took place between 2015 and 2019 and were valued at about $5,000, the company said. Arrow Electronics said it voluntarily disclosed the potential violations to the Treasury’s Office of Foreign Assets Controls and the Commerce Department Bureau of Industry and Security earlier this year. It also disciplined or fired employees involved in the transactions and said it plans to “cooperate fully” with BIS and OFAC. The company said it is not able to “estimate” the potential penalty it may receive.
The Treasury’s Office of Foreign Assets Control issued guidance on the definition of “maintenance” used in General License K, which allows certain transactions with COSCO Shipping Tanker (Dalian) Co. The guidance was released along with two new Frequently Asked Questions and two updated FAQs, according to a Nov. 27 notice.
The Treasury’s Office of Foreign Assets Control sanctioned Corporacion Panamericana, a Cuban company controlled by U.S.-sanctioned Cubametales, Treasury said Nov. 26. Since it was sanctioned, Cubametales has offered Corporacion Panamericana as an intermediary to companies who decline to do business with Cubametales.
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.
The Treasury’s Office of Foreign Assets Control sanctioned Mohammad Javad Azari Jahromi, Iran’s minister of Information and Communications Technology, Treasury said in a Nov. 22 press release. Azari Jahromi is in charge of a ministry that restricts the country’s internet use and blocked it for several days in November in the wake of anti-regime protests, Treasury said. The ministry also restricts “popular communication platforms,” Treasury said, and Azari Jahromi played a role in launching Iran’s National Information Network, which helps the government “monitor, restrict, and completely block internet usage.”
The Treasury’s Office of Foreign Assets Control is amending the Venezuela Sanctions Regulations by adding recent Venezuela-related executive orders, a recent general license and an “interpretive provision,” OFAC said in a Nov. 22 notice. OFAC is adding a general license “previously posted only on OFAC’s website” that authorizes certain U.S. government activities in Venezuela. The interpretive provision, which involves settlement agreements and enforcements of liens, judgments or “other orders through” the “judicial process,” clarified that the “entry into a settlement agreement … is prohibited unless authorized pursuant to a specific license issued by OFAC.”
A Virginia-based information technology company may have violated U.S. sanctions in 2017, the company said in a quarterly filing with the Securities and Exchange Commission for the period ended on Sept. 30. The company, DXC Technology, said it voluntarily disclosed possible violations to the Office of Foreign Assets Control stemming from “insurance premium data and claims data” processed by two partially owned joint ventures of Xchanging, a London technology company that DXC acquired in 2017. DXC also sent a copy of the disclosure to the United Kingdom’s Office of Financial Sanctions Implementation. The company said it is “finalizing its internal investigation” of the violations and plans to give OFAC more information in early 2020.
A South American airline may have violated U.S. sanctions against Cuba, the airline said in an October filing with the Securities and Exchange Commission. Avianca Holdings said it recently became subject to U.S. sanctions regulations when its parent company, Synergy Aerospace Corp., conducted a 2018 share-transfer with a Delaware-based company “wholly-owned” by Synergy, the filings said. Soon after the transfer, Avianca said it discovered its “regularly scheduled” flights between Central and South America and Cuba were subject to U.S. laws and may have violated the U.S. Cuban Assets Control Regulations.