The OverRuled: Sanctions Module has been updated with the following actions:
- 21 Dec 2023 - Privilege Underwriters Reciprocal Exchange - USD $466,200
Between May 2018 and July 2020, Privilege Underwriters Reciprocal Exchange engaged in transactions related to four insurance policies involving Medallion, Inc., a blocked Panama-based company owned by Specially Designated National Viktor Vekselberg.
The OverRuled: BIS Export Controls Module has been updated with the following actions:
- 21 Dec 2023 - Angel Huerta-Garay - Denial Order; No monetary penalty
On December 21, 2023, BIS issued a Denial Order against Angel Huerta-Garay ("Respondent") for a period of 10 years in relation to violations of 18 U.S.C. 554. The order went into effect on the Respondent's date of conviction on April 26, 2022. Specifically, the Respondent was convicted of exporting and sending, and attempting to export and send, various firearms from the United States to Mexico. The Respondent was sentenced to 52 months in prison, three years of supervised release, and a $100 special assessment. BIS did not impose any further monetary penalty on Respondent beyond the Court-imposed penalty.
- 21 Dec 2023 - Donald Robert Witherow - Denial Order; No monetary penalty
On December 21, 2023, BIS issued a Denial Order against Donald Robert Witherow ("Respondent") for a period of three 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 October 13, 2022. Specifically, the Respondent was convicted of smuggling firearms ammunition and firearms magazines from the United States to the Netherlands. The Respondent was sentenced to 12 months and one day of imprisonment, one year of supervised release and a $200 assessment. BIS did not impose any further monetary penalty on Respondent beyond the Court-imposed penalty.
- 21 Dec 2023 - Edson Daniel Montelongo - Denial Order; No monetary penalty
On December 21, 2023, BIS issued a Denial Order against Edson Daniel Montelongo ("Respondent") for a period of 10 years in relation to violations of 18 U.S.C. 554. The order went into effect on the Respondent's date of conviction on July 22, 2022. Specifically, the Respondent was convicted of smuggling various firearms from the United States to Mexico. The Respondent was sentenced to 70 months in prison, three years of supervised release, and a $500 special assessment. BIS did not impose any further monetary penalty on Respondent beyond the Court-imposed penalty.
- 21 Dec 2023 - Javier Alonso Galvan-Hernandez - Denial Order; No monetary penalty
On December 21, 2023, BIS issued a Denial Order against Javier Alonso Galvan-Hernandez ("Respondent") for a period of 10 years in relation to violations of 18 U.S.C. 554. The order went into effect on the Respondent's date of conviction on May 11, 2022. Specifically, the Respondent was convicted of smuggling various firearms from the United States to Mexico. The Respondent was sentenced to 84 months in prison, three years of supervised release, and a $200 special assessment. BIS did not impose any further monetary penalty on Respondent beyond the Court-imposed penalty.
- 21 Dec 2023 - Jonathan Yet Wing Soong - Denial Order; No monetary penalty
On December 21, 2023, BIS issued a Denial Order against Jonathan Yet Wing Soong ("Respondent") for a period of 10 years in relation to violations of the International Emergency Economic Powers Act (50 U.S.C 1701). The order went into effect on the Respondent's date of conviction on April 28, 2023. Specifically, the Respondent was convicted of knowingly and willfully exporting from the United States to Beihang University, an entity on the Department of Commerce’s Entity List, EAR99 CIFER (Comprehensive Identification from Frequency Responses) software, a tool that allows a user to develop a dynamic model of an aircraft using system identification techniques, without having first obtained the required authorization from the Department of Commerce The Respondent was sentenced to 20 months of imprisonment, three years of supervised release, $100 assessment and $168,885 in restitution.
- 21 Dec 2023 - Jose Luis Garcia - Denial Order; No monetary penalty
On December 21, 2023, BIS issued a Denial Order against Jose Luis Garcia ("Respondent") for a period of 10 years in relation to violations of 18 U.S.C. 371 and 18 U.S.C. 554(a). The order went into effect on the Respondent's date of conviction on December 14, 2021. Specifically, the Respondent was convicted of f conspiring to smuggle firearms from the United States to Mexico without first having obtained the required export license and authorization from the U.S. Department of State or U.S. Department of Commerce. The Respondent was sentenced to 57 months of imprisonment, three years of supervised release, $20,000 criminal fine and a $100 assessment.
- 21 Dec 2023 - Rolondo Alexei Pupo-Abrahantes - Denial Order; No monetary penalty
On December 21, 2023, BIS issued a Denial Order against Rolondo Alexei Pupo-Abrahantes ("Respondent") for a period of 10 years in relation to violations of 18 U.S.C. 371 and 18 U.S.C. 554. The order went into effect on the Respondent's date of conviction on November 16, 2022. Specifically, the Respondent was convicted of conspiring to smuggle various firearms from the United States to Ecuador. The Respondent was sentenced to 30 months in prison, two years of supervised release and a $300 special assessment. BIS did not impose any further monetary penalty on Respondent beyond the Court-imposed penalty.
- 21 Dec 2023 - Stephanie Joahna Gloria - Denial Order; No monetary penalty
On December 21, 2023, BIS issued a Denial Order against Stephanie Joahna Gloria ("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 May 23, 2022. Specifically, the Respondent was convicted of smuggling from the United States to Mexico 3,200 rounds of Winchester 5.56-millimeter ammunition. The Respondent was sentenced to 70 months of imprisonment, three years of supervised release, and a $100 assessment. BIS did not impose any further monetary penalty on Respondent beyond the Court-imposed penalty.
- 21 Dec 2023 - Tina Chen - No Denial Order; No monetary penalty
On December 21, 2023, BIS issued a Denial Order against Tina Chen (a/k/a Ya When Chen, a/k/a Wen Tina Chen, a/k/a Tina Dunbar, a/k/a Tina Dubner) ("Respondent") for a period of 10 years in relation to violations of the International Emergency Economic Powers Act (50 U.S.C 1701, et seq.). The order went into effect on the Respondent's date of conviction on February 23, 2023. Specifically, the Respondent was convicted of exporting goods from the United States to Iran without the required licenses from the Office of Foreign Assets Control. The Respondent was sentenced to 13 months of confinement, three years of supervised release, and a $100 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:
- 20 Dec 2023 (UK):
The Office of Financial Sanctions Implementation ("OFSI") updated both its UK Maritime Services Ban and Oil Price Cap – Industry Guidance (the "UK Price Cap Guidance") and its UK General Licence INT/2022/2469656 ("GL INT/2022/2469656") with respect to the UK's oil price cap regime. Among the provisions are guidelines on the future attestation model the UK will be introducing from February 19, 2024 onwards, clarification on the reporting obligations of UK nationals in third countries, and updates to the reporting and information recording obligations of in-scope persons.
- 19 Dec 2023 (EU):
The Council of the EU, together with the Commission, published its 12th round of sanctions including, inter alia, a total of 140 new designations (56 individuals and 87 entities), stricter obligations in respect of the re-export of critical and sensitive goods to Russia, enhanced reporting requirements under the G7+ oil price cap, stronger anti-circumvention measures that seek to enhance transparency and information sharing, and several products are now the subject of import and export controls (including new trade restrictions in respect of diamonds and diamond-jewellery), set out in Council Regulation (EU) 2023/2873 of 18 December 2023, Council Implementing Regulation (EU) 2023/2875 of 18 December 2023, Council Regulation (EU) 2023/2878 of 18 December 2023, Council Decision (CFSP) 2023/2871 of 18 December 2023, and Council Decision (CFSP) 2023/2874 of 18 December 2023.
In connection with these measures, the Council has introduced exemptions relating to personal items, such as personal hygiene, cars, as well as providing extended wind-down periods for the import of specific steel products.
- 11 Dec 2023 (UK):
The UK Department for Business & Trade published General Trade Licence "Russia Sanctions - Iron and steel products and relevant processed iron or steel products - Licence number: GBSAN0001" ("GTL"), which authorizes certain activities in respect of iron and steel products that would otherwise be prohibited under Regulations 46D, 46G, 46H and 46I of Chapter 4C (iron and steel products) or Regulations 46IB to 46IE of Chapter 4CA (iron and steel products processed in a third country) of The Russia (Sanctions) (EU Exit) Regulations 2019.
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