New Updates for 25-Oct-2023

2023-10-25

Reading Time : 4 min

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

  • 05 Oct 2023 - Dina Zhu - Denial Order; No monetary penalty

    On October 5, 2023, Dina Zhu ("Respondent") agreed to a 1-year denial order, with a suspended second year, as part of a Settlement Agreement with BIS in relation to one violation of the Export Administration Regulations. Specifically, on or about November 30, 2018, the Respondent attempted to export 0A987 optical sighting devices, worth a total of $25,000, from the United States to the Peoples Republic of China, via Hong Kong, without the required Department of Commerce export license (§ 764.2(c)). The Settlement Agreement does not indicate whether the Respondent filed a voluntary self-disclosure.

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

  • 16 Oct 2023 (UK):

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

    ​The Foreign, Commonwealth and Development Office ("FCDO") issued an e-alert following the Court of Appeal's judgement in the case of Mints & others v PJSC National Bank Trust & another.

    This was alert was issued in response to obiter in the case of Mints, which suggested that National Bank Trust ("NBT") should be treated as subject to the asset freeze by virtue of being owned or controlled by one or more DPs within the meaning of Regulation 7(4) of the Russia (Sanctions) (EU Exit) Regulations 2019, namely Vladimir Putin, the President of the Russian Federation, and Elvira Nabiullina, the Governor of the Central Bank of Russia ("CBR"). In January 2023, the High Court found that control held through political office fell outside Regulation 7(4), so Putin and Nabiullina did not control the CBR. However, the Court of Appeal concluded that NBT, and by implication the CBR, is controlled by Putin and/or Nabiullina for the purpose of the UK sanctions regime. However, the Court's findings on the ownership and control issue were obiter and so are non-binding on subsequent courts and UK persons. The FCDO has now issued a clarifying statement on the position.

  • 13 Oct 2023 (UK):

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

    ​The Office of Financial Sanctions Implementation ("OFSI") amended General Licence INT/2022/2300292 ("GL") in respect of payments made by a designated person ("DP") to energy companies for gas and electricity services. The GL is applicable to all UK Autonomous Sanctions Regulations listed within Annex I of the GL.

  • 12 Oct 2023 (OFAC):

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

    OFAC identified two vessels as blocked property (the "Blocked Vessels") and designated their respective owners, under E.O. 14024, for operating in the marine sector of the Russian Federation. According to OFAC, the two vessels carried Russian crude oil at prices above $60 per barrel, following the implementation of the price cap policy. These actions were taken as part of the U.S. Department of Treasury's commitment to reducing Russian oil profits and ensuring a reliable supply of crude oil and petroleum products to the global market.

    Concurrent with these actions, OFAC issued Russia General License 73, which authorizes the docking and anchoring of the Blocked Vessels, the preservation of the health of the Blocked Vessels' crew, emergency repairs of the Blocked Vessels, and environmental mitigation and protection activities relating to any of the Blocked Vessels until 12:01 a.m. Eastern Standard Time, January 8, 2024, subject to certain conditions.

  • 12 Oct 2023 (OFAC):

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

    The Price Cap Coalition, an international coalition including the United States, G7, European Union, and Australia, issued an Advisory for the Maritime Oil Industry and Related Sectors (the "Advisory") that highlights increased safety, environmental, economic, reputational, financial, logistical, and legal risk risks associated with the maritime oil industry and related sectors, and provides recommendations for best practices to prevent and disrupt sanctioned trade and enhance compliance with the price cap policy. The Advisory notes irregular and high-risk shipping practices common to the so-called "shadow" trade that pose significant concerns for both government and private industry participants. The Advisory provides seven specific recommendations for public and private sector actors to consider implementing to reduce risks while promoting the safe flow of oil on the market.

  • 10 Oct 2023 (UK):

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

    ​The Office of Financial Sanctions Implementation ("OFSI") amended General Licence INT/2023/3024200 ("GL") in respect of Prior Obligations, which was issued pursuant to Regulation 64 of The Russia (Sanctions) (EU Exit) Regulations 2019 ("Russia Regulations") and Regulation 32 of The Republic of Belarus (Sanctions) (EU Exit) Regulations 2019​ ("Belarus Regulations"). The GL permits a UK person who is owed funds or economic resources by a designated person ("DP"), under a contract that was signed before the DP in question was designated, to receive payment, provided that the terms of GL INT/2023/3024200 are met.

Please send an email to subscriptions@overruled.com, if you would like information on how to subscribe to access additional detail about these and other sanctions- and export controls-related actions. If you are already a paid subscriber, please login to OverRuled for access to exclusive content, analysis, and historic search functionality.

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