US indicts 3 people for violating Iran export controls

US DoJ.jpgThe US has indicted 3 US citizens – Sadr Emad-Vaez, Pouran Aazad, and Hassan Ali Moshir-Fatemi – for violating export control laws under the International Emergency Economic Powers Act. Specifically, for allegedly engaging in transactions involving the illegal export of goods and services to Iran and financial transactions designed to evade the Iranian Transactions Sanctions Regulations. US Department of Justice press release here.

OFSI renews TAFA designation

OFSI1.jpegThe UK Office of Financial Sanctions Implementation (OFSI) has renewed the terrorist listing of Mohammed Fawaz Khaled under the Terrorist Asset-Freezing etc. Act 2010 (TAFA). He was assessed as having “left the UK and travelled to Syria to engage in Islamist extremist activities on behalf of ISIL”, with his current whereabouts “now in Turkey”.

The OFSI Notice explains that his renewed designation may be appealed to the High Court (or, in Scotland, to the Court of Session) under section 26 of TAFA.

OFAC sanctions Chinese “fentanyl trafficking network”

US Treasury BuildingToday, OFAC designated Chinese national Jian Zhang as a Significant Foreign Narcotics Trafficker, pursuant to the US Kingpin Act, for operating a “fentanyl trafficking network”. In addition, OFAC designated 4 further Chinese nationals for “acting on behalf of Jian Zhang”, as well as a Hong Kong registered entity (Zaron Bio-Tech (Asia) Limited) for being “owned or controlled by Jian Zhang”. As a result, all will be subject to asset freezing measures. Links to OFAC Notice and US Treasury press release.

OFAC lifts sanctions on Colombian professional football team

Football pitch.jpgYesterday, OFAC lifted sanctions on the Colombian professional football team, Envigado Futbol Club S.A., due to it recently completing a sale and restructuring of team management, under the oversight of the Colombian government, that “eliminated ties to a Colombian crime group involved in international narcotics trafficking and other criminal activities and cut them off from any benefit from the sale”.

The football team was originally designated in November 2014, pursuant to the Foreign Narcotics Kingpin Designation Act, for being “owned, controlled, or directed by, or acting for or on behalf of, La Oficina de Envigado and Juan Pablo Upegui Gallego” (both Specially Designated Narcotics Traffickers). Links to OFAC Notice and US Treasury press release.

EU implements UN amendment to Afghanistan listing

EU CommissionEarlier this month, the UN Security Council amended the listing of Mohammed Omar Ghulam Nabi under its Afghanistan sanctions by altering his UN designation date from 31 January 2001 to 12 April 2000. UN press release here.

Today, the EU has implemented that UN amendment by adopting Council Implementing Decision (CFSP) 2018/656 and Council Implementing Regulation (EU) 2018/648.

US investigates China’s Huawei Technologies over Iran sanctions violations

Huawei.jpgChinese tech company Huawei Technologies is reportedly being investigated by the US Department of Justice for violating sanctions on Iran; namely, for shipping US-origin products to Iran and other countries in violation of US export and sanctions laws.

EU extends Burma arms embargo & adopts framework to impose targeted measures


The EU has continued for 1 year its arms embargo on Burma/Myanmar, and has expanded it to include:


1.      A prohibition on the export of dual-use goods for use by the military and border guard police;

2.      Restrictions on the export of equipment for monitoring communications that might be used for internal repression; and

3.      A prohibition on the provision of military training to, and military cooperation with, the Burma/Myanmar army.

The EU has also adopted a legal framework to impose targeted sanctions (travel bans and asset freezes) against individuals of the Myanmar Armed Forces (Tatmadaw) and the border guard police who are deemed responsible for (inter alia) “serious human rights violations” (no individuals or entities listed yet). The EU previously had targeted sanctions in place against Burma/Myanmar but were completely lifted in April 2013 (previous blog here).

These EU measures were adopted today as a result of the Foreign Affairs Council conclusions of 26 February 2018 on the situation in Burma/Myanmar (previous blog here). See Council Decision (CFSP) 2018/655 and Council Regulation (EU) 2018/647. EU press release here, and UK OFSI Notice here.

US concludes $30m settlement with FLIR Systems Inc. for alleged export violations

US Department of StateThe US Department of State has reached an agreement with FLIR Systems Inc (Wilsonville, Oregon) to settle allegations that it violated the International Traffic in Arms Regulations (ITAR) in connection with unauthorised exports of defence articles; the unauthorised provision of defence services; violation of the terms of provisos or other limitations of licence authorisations; and the failure to maintain specific records involving ITAR-controlled transactions.

Under the terms of the four-year Consent Agreement, FLIR will pay a civil penalty of $30 million. The Department of State has agreed to suspend $15 million of that amount on the condition that the funds have or will be used for Department-approved Consent Agreement remedial compliance measures. FLIR must also hire an external Designated Official to oversee the Consent Agreement, which would require the company to conduct two external audits to assess and improve its compliance program during the agreement term as well as implement additional compliance measures. Department of State press releases here and here.