OFAC has fined American Export Lines (AEL), a US-based international freight forwarding and logistics company, $518,063 for violating US sanctions on Iran. The violations, which AEL did not voluntarily disclose, are said to have occurred when AEL transhipped used and junked cars and parts from the US via Iran to Afghanistan on 140 occasions. AEL’s conduct was aggravated by the fact that its President and co-owner knew and approved of the transhipments via Iran, but mitigated by the fact that none of the shipments appear to have had an end use in that country.
OFAC’s enforcement notice is here.
IPSA International Services, Inc., a US-based risk management firm, has been fined $259,200 by OFAC for violating US sanctions on Iran. The violations, worth $290,784, are said to have occurred when IPSA assisted two countries with their citizenship by investment programmes. Some of the applicants to the programmes were Iranian nationals and, because most of the information about them could not be checked or verified from outside of Iran, IPSA and its subsidiaries engaged subcontractors, who in turn hired third parties, to validate their information. As a result, OFAC found that IPSA had directly imported Iranian-origin services into the United States, or done so indirectly by reviewing, approving, and initiating payments to the providers of the Iranian origin services by its foreign subsidiaries.
The base penalty amount was $720,000 and the maximum penalty available was $18,000,000. In aggravation, OFAC found that IPSA had not voluntarily disclosed the violations, that at least one of its senior management knew or had reason to know of the violations, and that the underlying conduct was not eligible for OFAC authorisation under an existing licence. In mitigation, OFAC said that IPSA had substantially cooperated with its investigation and taken significant remedial measures to prevent further violations from occurring in the future.
Iran has banned 2 members of its national football team, including its captain for life, after they played in a match between their Greek club Panionios and Israeli team Maccabi Tel Aviv. Iran has said their participation in the game violated a longstanding unwritten rule that Iranian sportspeople should not compete against their Israeli counterparts.
In 2013, the United States published Iran General Licence F, which authorises US sportspeople to participate in competitions involving Iran.
Iran’s President Hassan Rouhani has said that Iran will restart its nuclear programme “within hours” if the US imposes new sanctions on Iran. Since the JCPOA came into force at the start of 2016, Iran has conducted several ballistic missile tests. The US believes that the tests violate UN sanctions, which prohibit “any activity related to ballistic missiles designed to be capable of delivering nuclear weapons”. Iran has said that any new sanctions breach the JCPOA and that its ballistic missiles are not designed to carry nuclear warheads.
The US designated 14 more Iranian people and entities in July for (among other things) involvement in Iran’s ballistic missile programme (see previous blog).
President Trump today signed a bill passed by Congress last week, which imposes new sanctions on Russia, Iran, and North Korea (see previous blog). The Countering America’s Adversaries Through Sanctions Act restricts the President’s ability to lift sanctions without Congressional approval. President Trump’s statement on signing the Act makes the following remarks:
“…the bill remains seriously flawed – particularly because it encroaches on the executive branch’s authority to negotiate… By limiting the Executive’s flexibility, this bill makes it harder for the United States to strike good deals for the American people, and will drive China, Russia, and North Korea much closer together. The Framers of our Constitution put foreign affairs in the hands of the President. This bill will prove the wisdom of that choice.
Yet despite its problems, I am signing this bill for the sake of national unity. It represents the will of the American people to see Russia take steps to improve relations with the United States. We hope there will be cooperation between our two countries on major global issues so that these sanctions will no longer be necessary… I built a truly great company worth many billions of dollars. That is a big part of the reason I was elected. As President, I can make far better deals with foreign countries than Congress.”
In response to the bill passing through Congress, Russia ordered the expulsion of 755 US diplomatic staff from the country.
On Friday, the USA imposed sanctions on 6 subsidiaries of Shahid Henmat Industrial Group, in response to Iran’s rockets test last week that the USA, France, Germany and the UK said was inconsistent with a UN Security Council resolution calling on Iran not to conduct tests of that kind. The 6 Shahid Hemmat units manufacture missile components, missile airframes, liquid-propellant ballistic missile engines, liquid propellant, guidance and control systems, and undertake missile-related research and maintenance.
On Tuesday, the US House of Representatives voted overwhelmingly in favour of imposing new sanctions on Russia, Iran, and North Korea (see previous blog). That bill has now also passed the US Senate, and will go before President Trump for his signature.
In response, Russia has instructed the US to reduce the number of its diplomatic personnel in Russia to 455 at any given time, and has seized holiday properties and a warehouse used by US personnel. It is reported that there are currently over 1000 staff working at the US embassy in Moscow and its 3 Russian consulates.
The US House of Representatives has overwhelmingly (419-3) passed legislation which imposes new sanctions on Russia (for involvement in the 2016 election), Iran, and North Korea, and require the President to obtain approval from Congress before lifting US sanctions. The US Senate recently passed a similar bill (see previous blog), but the House amended the legislation before passing it and so it must now return to the Senate for approval. The White House has expressed concerns that the Bill will restrict a President’s ability to conduct foreign policy, but has not yet indicated whether President Trump will sign the legislation.
The EU has raised concerns about these new US sanctions (see previous blog), saying that it stands ready to retaliate if the US imposes new sanctions on Russia without first addressing Europe’s concerns. EU Commissioners have been briefed that several EU energy and infrastructure projects, including a multibillion-euro pipeline involving Russia, could be affected by the sanctions in their current form.