New Updates for 15-Feb-2024

2024-02-15

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

  • 12 Feb 2024 - Cargosave, Inc. - Denial Order; No monetary penalty

    On February 12, 2024, Cargosave, Inc. (“Respondent”) agreed to a suspended 2-year denial order as part of a Settlement Agreement with BIS in relation to 2 violations of the Export Administration Regulations. Specifically, between on or about September 7, 2016 and December 10, 2016, the Respondent was involved caused, aided, and abetted acts prohibited by the Export Administration Regulations, facilitating the export of enterprise servers and switches classififed under Export Control Classification numbers 4A994.b, 5A002.a, 5A991,b, and 5A992.c, from the United States to Iran, worth a total of $17,408, without licenses. In addition, the Respondent shall complete export compliance training on the Export Adminsitration Regulations within 12 months of the date of the order.

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

  • 12 Feb 2024 (BIS):

    ​The Department of Justice ("DOJ") announced that Kristina Puzyreva, a Russian-Canadian national, pleaded guilty to money laundering conspiracy related to a scheme to evade U.S. sanctions and export controls by unlawfully shipping millions of dollars of U.S. electronics to end users in Russia with links to the Russian military.

  • 01 Feb 2024 (OFAC):

    The Akin Summary document has now been posted for this action.

    The Price Cap Coalition, an international coalition, including the United States, the G7, the European Union, and Australia, that have agreed to administer and enforce the Russian oil and petroleum price cap policy issued an Oil Price Cap ("OPC") Compliance and Enforcement Alert (the "Alert") that includes an overview of key OPC evasion methods, recommendations for identifying such methods and mitigating their risks, and information on how to remediate and report suspected breaches of OPC. The Alert covers OPC evasion methods related to falsified documentation and attestations, opaque shipping and ancillary costs, third country supply chain intermediaries and complex and irregular corporate structures, flagging, the "shadow" fleet, and voyage irregularities. The Alert is part of the Price Cap Coalition's continued multijurisdictional efforts to administer and enforce the OPC, including by relevant regulators such as the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC"), the UK’s Office of Financial Sanctions Implementation ("OFSI"), and the EU Commission.

  • 01 Feb 2024 (EU):

    The Akin Summary document has now been posted for this action.

    The Price Cap Coalition, an international coalition, including the United States, the G7, the European Union, and Australia, that have agreed to administer and enforce the Russian oil and petroleum price cap policy issued an Oil Price Cap ("OPC") Compliance and Enforcement Alert (the "Alert") that includes an overview of key OPC evasion methods, recommendations for identifying such methods and mitigating their risks, and information on how to remediate and report suspected breaches of OPC. The Alert covers OPC evasion methods related to falsified documentation and attestations, opaque shipping and ancillary costs, third country supply chain intermediaries and complex and irregular corporate structures, flagging, the "shadow" fleet, and voyage irregularities. The Alert is part of the Price Cap Coalition's continued multijurisdictional efforts to administer and enforce the OPC, including by relevant regulators such as the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC"), the UK’s Office of Financial Sanctions Implementation ("OFSI"), and the EU Commission.

  • 01 Feb 2024 (UK):

    The Akin Summary document has now been posted for this action.

    The Price Cap Coalition, an international coalition, including the United States, the G7, the European Union, and Australia, that have agreed to administer and enforce the Russian oil and petroleum price cap policy issued an Oil Price Cap ("OPC") Compliance and Enforcement Alert (the "Alert") that includes an overview of key OPC evasion methods, recommendations for identifying such methods and mitigating their risks, and information on how to remediate and report suspected breaches of OPC. The Alert covers OPC evasion methods related to falsified documentation and attestations, opaque shipping and ancillary costs, third country supply chain intermediaries and complex and irregular corporate structures, flagging, the "shadow" fleet, and voyage irregularities. The Alert is part of the Price Cap Coalition's continued multijurisdictional efforts to administer and enforce the OPC, including by relevant regulators such as the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC"), the UK’s Office of Financial Sanctions Implementation ("OFSI"), and the EU Commission.​

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