The OverRuled: BIS Export Controls Module has been updated with the following actions:
- 20 Dec 2024 - Unicat Catalyst Technologies, LLC - Denial Order; USD $391,183
(Note: BIS did not publish this enforcement action on its website until June 2025.) On December 20, 2024, BIS issued an order approving a settlement between BIS and Unicat Catalyst Technologies, LLC (the “Respondent”) in connection with violations of 15 C.F.R. § 764.2(e). Respondent acquired a predecessor entity, Legacy Unicat, in September 2020. On three occasions between on or about October 2017 through on or about September 2020, the predecessor entity exported EAR99 catalysts valued at $391,182.78 to Iran without authorization. As part of the BIS settlement and order, Respondent was assessed a civil penalty of $391,183.00. Additionally, BIS issued against Respondent a 3-year Suspended Denial Order. The Order is suspended for a 3-year probationary period, provided that Respondent does not commit additional violations of ECRA or the Regulations. Respondent separately entered into a settlement agreement with the Office of Foreign Assets Control (OFAC) and a Non-Prosecution Agreement (NPA) with the Department of Justice (DOJ) concerning the same conduct. Respondent and OFAC entered into a settlement agreement that imposed a civil penalty of $3,882,797.00. Payment of the OFAC civil penalty will be credited towards the $391,183.00 BIS penalty amount due, which becomes immediately due if Respondent fails to pay the OFAC civil penalty.
The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 27 Jun 2025 (UK):
The Office of Financial Sanctions Implementation ("OFSI") amended General Licence INT/2022/2470156, which permits in respect of specific projects listed in Schedule 1 of the Licence (i) the supply or delivery of Russian oil by ship from a place in Russia to a third country or from one third country to another third country; and (ii) a service provider to provide relevant services to any person (whether or not a UK Person) relating to the supply or delivery of Russian oil by ship from a place in Russia to a third country or from one third country to another third country.
- 27 Jun 2025 (UK):
The Office of Financial Sanctions Implementation ("OFSI") amended General Licence INT/2025/5635700, which allows for the continuation of business operations with Gazpromneft-Sakhalin LLC, to the extent they are in relation to the Exempt Projects (as defined under General Licence INT/2025/5635700).
- 27 Jun 2025 (UK):
The Foreign, Commonwealth and Development Office ("FCDO") published new sanctions guidance to support non-UK businesses.
The guidance specifically concerns sanctions targeting Russia and summarizes the scope and requirements of UK sanctions, and outlines the risks of non-compliance for non-UK businesses. The guidance provides practical advice on how to implement good compliance practices, and mitigate the circumvention of UK sanctions. The guidance includes country-specific guides for businesses in Armenia, Georgia, Kazakhstan, Kyrgyzstan, and Uzbekistan. The guidance is general, so relevant up-to-date legislation should be consulted.
- 27 Jun 2025 (OFAC):
The Akin Summary document has now been posted for this action.
The U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") issued Russia-related General License ("GL"), 115B, "Authorizing Certain Transactions Related to Civil Nuclear Energy", and made technical/non-substantive edits to ten FAQs.
- 26 Jun 2025 (BIS):
The U.S. Department of Justice (“DOJ”) announced that Sergei Zharnovnikov, a Kyrgyz national, pleaded guilty to conspiracy to violate U.S. export controls in connection with a scheme to reexport firearms and ammunition worth over $1.5 million from the United States to Russia (via Kyrgyzstan) without authorization.
- 17 Jun 2025 (BIS):
The U.S. Department of Justice (“DOJ”) announced that Bence Horvath, a Spanish national and resident of the United Arab Emirates, pleaded guilty to conspiracy to violate U.S. export controls in connection with a scheme to unlawfully export military-grade radio communications technologies to Russian end-users without authorization. Horvath’s guilty plea follows his arrest on August 26, 2024.
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