Following US President Trump’s decision not to certify Iran’s compliance with the JCPOA (see previous blog here), the EU has issued a press release saying it is “committed to the continued full and effective implementation of all parts of the JCPOA” and that the US decision is “an internal US process”. The EU encourages the US to “maintain its commitment to the JCPOA and to consider the implications for the security of the US, its partners and the region before taking further steps.” It repeats the need to address concerns related to ballistic missiles and increasing tensions in the region outside the JCPOA, “in the relevant formats and fora”. It further states that “at a time of acute nuclear threat the EU is determined to preserve the JCPOA as a key pillar of the international non-proliferation architecture.”
The US Office of Foreign Assets Control (OFAC) has designated the Islamic Revolutionary Guard Corps (IRGC) under Executive Order 13224 for its “activities in support of the IRGC-Qods Force… for providing support to a number of terrorist groups, including Hizballah and Hamas, as well as to the Taliban”. OFAC also designated 4 other entities (Shahid Alamolhoda Industries, Rastafann, Ranamoj and Wuhan Sanjiang Import and Export Co Ltd) under EO 13382, which targets WMD proliferators and their supporters, for their support to the IRGC or the Iranian military. For the OFAC press release, click here.
President Trump announced in a speech today that he will not scrap the JCPOA (he wants strict compliance with it) but will not certify that Iran is complying with it, which means that Congress now has 60 days to decide whether to re-impose sanctions. The President has unveiled a new “strategy” document on Iran. A joint statement by EU leaders May, Macron & Merkel expresses concern about his decision.
The EU has published a Notice amending the terrorist asset freeze listings of 8 people in light of new information and has said that they can request the updated statements of reasons by 16 October and ask the Council to reconsider their listing by 8 November. For the EU terrorism list, see the Annex to Council Implementing Regulation (EU) 2017/1420.
The UN Security Council has banned 4 ships from entering any port for breaching sanctions on DPRK from 5 October. The ships, identified as the Petrel 8, Hao Fan 6, Tong San 2 and Jie Shun, had transported prohibited goods to and from DPRK. For the UN press release, see here.
Last week 3 people pleaded guilty to conspiracy to defraud and exporting prohibited articles to Syria in violation of US export control laws, in the District Court for the Southern District of Florida. Aviation parts and equipment are alleged to have been exported without a licence to Syrian Arab Airlines (Syrian Air), the Syrian Government’s airline, which had been listed as an SDN by OFAC for transporting weapons and ammunition to Syria in conjunction with Hizballah and the Iranian Revolutionary Guard Corps. The defendants are to be sentenced on 19 December. For the US Department of Justice press release, click here.
US President Trump must decide by 15 October whether he will certify to Congress that Iran is complying with its obligations set out in the nuclear deal (JCPOA). He has previously certified that it has done so twice before, in April and July 2017. If the President does not certify, Congress has 60 days to decide whether to re-impose sanctions on Iran.
The US has also indicated that it may designate Iran’s Islamic Revolutionary Guard Corps (IRGC) as a terrorist group. In response, the IRGC Commander warned that, if designated, the military wing would treat US troops, particularly those in the Middle East, as if they were Islamic State terrorists.
BD White Birch Investment LLC (White Birch USA), a company headquartered in Greenwich, Connecticut, has agreed to pay OFAC $372,465 to settle allegations that it violated the Sudanese Sanctions Regulations by having facilitated the sale and shipment of 543.952 metric tons of Canadian-origin paper from Canada to Sudan with a value of $354,602.26 in April and December 2013.
The enforcement action reinforces certain compliance obligations for US persons, including US parent corporations that maintain subsidiaries located outside of the United States, and their US person employees. For the full enforcement information, released on 5 October 2017, click here.