The OverRuled: BIS Export Controls Module has been updated with the following actions:
- 10 Aug 2023 - Guiliano Pecci - Denial Order; No monetary penalty
On August 10, 2023, BIS issued a Denial Order against Guiliano Pecci ("Respondent") for a period of seven years in relation to violations of 18 U.S.C. § 554(a). The order went into effect on the Respondent's date of conviction on March 31, 2022. Specifically, the Respondent was convicted of smuggling firearm kits from the United States to Paraguay. The Respondent was sentenced to 18 months of confinement, three years of supervised release and a $200 assessment. BIS did not impose any further monetary penalty on Respondent beyond the Court-imposed penalty.
- 10 Aug 2023 - Bradley Jon Matheny - Denial Order; No monetary penalty
On August 10, 2023, BIS issued a Denial Order against Bradley Jon Matheny ("Respondent") for a period of seven years in relation to violations of 18 U.S.C. § 554(a). The order went into effect on the Respondent's date of conviction on November 12, 2021. Specifically, the Respondent was convicted of smuggling from the United States to Arad, Israel, .117 caliber hunting pellets and smuggling from the United States to Sderot, Israel and Scottsville, South Africa, a Winchester 42-piece firearm brush cleaning kit. The Respondent was sentenced to 36 months of confinement, three years of supervised release, $1000 assessment, $10,000 criminal fine and $256,441.78 in restitution. BIS did not impose any further monetary penalty on Respondent beyond the Court-imposed penalty.
- 10 Aug 2023 - Vladimir Volgaev - Denial Order; No monetary penalty
On August 10, 2023, BIS issued a Denial Order against Vladimir Volgaev ("Respondent") for a period of 10 years in relation to violations of 18 U.S.C. § 554(a). The order went into effect on the Respondent's date of conviction on August 4, 2020. Specifically, the Respondent was convicted of smuggling and attempting to smuggle firearm parts from the United States to Ukraine without having obtained a license or other approval from the U.S. Department of State. The Respondent was sentenced to 33 months of confinement, one year of supervised release, $200 assessment and $6,835 in restitution. BIS did not impose any further monetary penalty on Respondent beyond the Court-imposed penalty.
- 10 Aug 2023 - Omran Ismail - Denial Order; No monetary penalty
On August 10, 2023, BIS issued a Denial Order against Omran Ismail ("Respondent") for a period of seven years in relation to violations of 18 U.S.C. § 371. The order went into effect on the Respondent's date of conviction on December 3, 2019. Specifically, the Respondent was convicted of conspiring to straw purchase several handguns on behalf of co-defendant Ola Sayed, who allegedly tried to smuggle the firearms into Egypt. The Respondent was sentenced to 18 months in prison, one year of supervised release, and an assessment of $200. BIS did not impose any further monetary penalty on Respondent beyond the Court-imposed penalty.
- 10 Aug 2023 - Emilie Voissem - Denial Order; No monetary penalty
On August 10, 2023, BIS issued a Denial Order against Emilie Voissem ("Respondent") for a period of seven years in relation to violations of g 18 U.S.C. § 371, the International Emergency Economic Powers Act (50 U.S.C § 1701, et seq.) (“IEEPA”) and 18 U.S.C. § 554. The order went into effect on the Respondent's date of conviction on January 12, 2022. Specifically, the Respondent was convicted of conspiracy to violate IEEPA, exporting and attempting to export, and smuggling four (4) rEvo III rebreathers from the United States to Libya without the required license or written approval. The Respondent was sentenced to five months in prison, three years of supervised release and a $300 special assessment. BIS did not impose any further monetary penalty on Respondent beyond the Court-imposed penalty.
The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 11 Aug 2023 (OFAC):
On August 11, 2023, OFAC designated four individuals and one entity under E.O. 14024. The action targets prominent Russian businesspersons, including Petr Olegovich Aven, Mikhail Maratovich Fridman, German Borisovich Khan, and Alexey Viktorovich Kuzmichev, all of whom serve on the supervisory board of the Alfa Group Consortium; such individuals had already been sanctioned in a number of other jurisdictions including the EU, UK, Australia, Canada, and New Zealand. OFAC also designated a Russian business association that has reportedly been involved in Russia's responses to sanctions imposed by the U.S. and its allies.
OFAC also issued a frequently asked question concurrently, FAQ 1131, which makes clear that LetterOne Holdings S.A. is not blocked, as such entity is not owned 50 percent or more by blocked persons, according to information available to OFAC.
- 11 Aug 2023 (UK):
The UK Secretary of State has issued a General Trade Licence (“GTL”) effective from August 11, 2023, and has published guidance in respect of the prohibition against the provision of Legal Advisory Services ("LAS") under Regulation 54D of The Russia (Sanctions) (EU Exit) Regulations 2019. The GTL addresses concerns raised by The Law Society and lobbying groups that the drafting of the LAS restriction prevented UK persons from providing compliance advice in respect of proposed activities prohibited under sanctions regimes implemented by other jurisdictions.
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