New Updates for 03-Jul-2025

2025-07-03

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The OverRuled: Sanctions Module has been updated with the following actions:

  • 02 Jul 2025 - Key Holding, LLC - USD $608,825

    Between January 2022 and July 2023, Key Holding, LLC's Colombian subsidiary, then called Key Logistics Colombia S.A.S., managed the logistics for 36 freight shipments, worth $3,056,264, from Colombia to Cuba.

The OverRuled: BIS Export Controls Module has been updated with the following actions:

  • 27 Jun 2025 - Alpha and Omega Semiconductor Incorporated - No Denial Order; USD $4,250,000

    BIS issued an order approving a settlement between BIS and Alpha and Omega Semiconductor Incorporated (the "Respondent") in connection with violations of 15 C.F.R. §§ 764.2(a) and 764.2(e). Specifically, on 15 occasions between on or about May 28, 2019, and on or about November 22, 2019, the Respondent forwarded from the United States approximately 1,650 power controllers, smart power stages, and related accessories to Huawei Technology Co. Ltd., a company listed on the BIS Entity List, without the required authorization from BIS. The items were foreign-designed and foreign-produced, and when subject to the EAR, they were designated as EAR99. The items in the transactions at issue were subject to the EAR because the Respondent exported them from the United States. As part of the settlement and order, the Respondent was assessed a civil penalty of $4,250,000.00.

The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:

  • 01 Jul 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") designated four individuals and four entities. The designations (targeting Aeza Group and affiliated entities and individuals facilitating cybercrime) were done pursuant to Executive Order ("E.O.") 13694.

Please send an email to subscriptions@overruled.com if you would like information on how to subscribe to access additional detail about these and other sanctions- and export controls-related actions. If you are already a paid subscriber, please login to OverRuled for access to exclusive content, analysis, and historic search functionality.

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