The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 20 Dec 2023 (OFAC):
OFAC updated its guidance on the implementation of the price cap policy for Russian-origin crude oil and petroleum products. The guidance now, among other things, requires that, in some situations, certain Price Cap Coalition service providers receive attestations within a specified timeframe that are related to the lifting and loading of Russian oil or petroleum products from counterparties and retain, provide, or receive certain ancillary cost information.
- 20 Dec 2023 (OFAC):
OFAC identified one vessel as blocked property ("Blocked Vessel") and designated four entities based in the UAE and Hong Kong under E.O. 14024. OFAC designated the Blocked Vessel's UAE-based owner for being owned by the Government of Russia and designated the remaining three entities for being oil traders who have frequently participated in the seaborne transportation of Russian-origin oil following the price cap policy's implementation. These actions were taken to tighten enforcement of the price cap on Russian-origin oil and petroleum products.
Concurrent with these actions, OFAC issued two general licenses: (i) General License 81, which authorizes certain safety and environmental transactions with any vessels in which the blocked persons or entities specifically enumerated in the general license has a property interest ("GL 81 Blocked Vessels"), including transactions related to the health or safety of the GL 81 Blocked Vessels' crew, emergency repairs of the GL 81 Blocked Vessels, and environmental mitigation and protection activities relating to the GL 81 Blocked Vessels through 12:01 a.m. Eastern Daylight Time, March 19, 2024, subject to certain conditions; and (ii) General License 82, which authorizes the wind down of transactions involving SUN Ship Management D Ltd and any entity it owns, directly or indirectly, 50% or more through 12:01 a.m. Eastern Daylight Time, March 19, 2024, subject to certain conditions.
- 19 Dec 2023 (BIS):
Following a 13-count indictment unsealed by the Department of Justice ("DOJ") in March 2023, on December 19, 2023, Cyril Gregory Buyanovsky pleaded guilty to conspiracy to circumvent U.S. export controls. According to the DOJ, Buyanovsky and Douglas Edward Robertson, used KanRus Trading Company, Inc. ("KanRus"), an entity they owned, to send sophisticated, U.S.-origin and controlled avionics equipment from the United States to Russia, and to Russian end users outside of Russia, without proper authorization.
The OverRuled: China Trade Controls Resource Center has been updated with the following actions:
- 20 Dec 2023 (OFAC):
OFAC designated two entities in Hong Kong, pursuant to EO 14024, among other parties in the UAE, for participating in the seaborne transportation of Russian-origin oil following the imposition of the price cap.
The listed entities in Hong Kong are:
- Bellatrix Energy Limited; and
- Covart Energy Limited
- Bellatrix Energy Limited; and
- 19 Dec 2023 (BIS):
BIS added 13 persons to the Unverified List ("UVL"), all under the destination of the PRC.
These foreign entities were added to the UVL because, as of publication, BIS or federal officials acting on BIS's behalf were unable to verify their bona fides (i.e., legitimacy and reliability relating to the end use and end user of items subject to the EAR) through the completion of an end-use check.
- 19 Dec 2023 (OFAC):
OFAC designated three entities in Hong Kong, pursuant to EO 13382, among other parties in Iran, Malaysia, and Indonesia, for facilitating the procurement of U.S.- and foreign- origin components for the Islamic Revolutionary Guard Corps Aerospace Force Self Sufficiency Jihad Organization and its unmanned aerial vehicle program.
The listed entities in Hong Kong are:
- Dirac Technology HK Limited;
- Integrated Scientific Microwave Technology SDN BHD (Malaysia- and Hong Kong-based); and
- Arta Wave SDN BHD (Malaysia- and Hong Kong-based)
- Dirac Technology HK Limited;
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