The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 06 Mar 2024 (BIS):
The U.S. Departments of Commerce, Treasury, and Justice issued a Tri-Seal Compliance Note ("Note") on the obligations of foreign-based companies and individuals to comply with U.S. sanctions and export controls. The Note provides a high-level overview of the applicability of U.S. sanctions and export controls to foreign persons, identifies examples of civil and criminal enforcement actions against foreign persons for alleged violations, and highlights general compliance considerations.
- 06 Mar 2024 (OFAC):
The Akin Summary document has now been posted for this action.
The U.S. Departments of Commerce, Treasury, and Justice issued a Tri-Seal Compliance Note ("Note") on the obligations of foreign-based companies and individuals to comply with U.S. sanctions and export controls. The Note provides a high-level overview of the applicability of U.S. sanctions and export controls to foreign persons, identifies examples of civil and criminal enforcement actions against foreign persons for alleged violations, and highlights general compliance considerations.
- 22 Feb 2024 (EU):
The European Commission, in coordination with its international partners in the U.S. and UK, increased the number of items on the EU's List of Common High Priority Items ("CHPI") from 45 to 50, to highlight additional dual-use goods and technology items that Russia is seeking to procure via non-sanctioned countries to develop its military and industrial complex. These items include electronic components such as integrated circuits and radio frequency transceiver modules, as well as items essential for the manufacturing and testing of the electronic components of the printed circuit boards, and manufacturing of high precision complex metal components retrieved from the battlefield in Ukraine.
- 22 Feb 2024 (UK):
The UK, together with the U.S. and EU, has increased the number of items on the UK's Common High Priority Items List ("CHPI") from 45 to 50, to highlight additional types of items that Russia is seeking to procure via non-sanctioned countries to wage its war in Ukraine.
The OverRuled: China Trade Controls Resource Center has been updated with the following actions:
- 06 Mar 2024 (OFAC):
OFAC designated two Hong Kong- and Marshall Islands-based ship owners and two vessels, pursuant to EO 13224, for shipments of Iranian commodities undertaken by the network of Iran-based, Islamic Revolutionary Guard Corps-Qods Force-backed Houthi financial facilitator Sa'id al-Jamal. The revenue generated through al-Jamal's network continues to enable Houthi militant efforts, including ongoing and unprecedented attacks on international maritime commerce in the Red Sea and Gulf of Aden.
The listed Hong Kong-based entity is Hongkong Unitop Group Ltd. The Panama-flagged vessel ETERNAL FORTUNE is identified as property in which Hongkong Unitop Group Ltd has an interest.
- 06 Mar 2024 (BIS):
The U.S. Departments of Commerce, Treasury, and Justice issued a Tri-Seal Compliance Note ("Note") on the obligations of foreign-based companies and individuals to comply with U.S. sanctions and export controls. The Note provides a high-level overview of the applicability of U.S. sanctions and export controls to foreign persons, identifies examples of civil and criminal enforcement actions against foreign persons for alleged violations, and highlights general compliance considerations.
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