By Jennifer Diaz|2022-12-25T23:20:15-05:00October 14, 2022|AD/CVD, EAR, HTS, Import Alert, International Trade, IRAN, People's Republic of China, Russian Harmful Foreign Activities Sanctions Regulations, SDN List, Special 301, Trade Policy, U.S. Bureau of Industry and Security (BIS), U.S. Customs and Border Protection (CBP), U.S. Department of Commerce (DOC), U.S. Department of Labor (DOL), U.S. Food and Drug Administration (FDA), U.S. International Trade Commission (USITC), U.S. Office of Foreign Assets Control (OFAC), U.S. Trade Representative (USTR)|Comments Off on Customs and Trade Law Weekly Snapshot
Vegas Woman Charged with Iran Sanctions Violations
A Las Vegas woman has been indicted by a federal grand jury for conspiracy to export goods from the United States to Iran, in violation of the International Emergency Economic Powers Act (IEEPA) and the Iranian Transactions and Sanctions Regulations. According to the indictment unsealed recently, Tina Chen, 47 — aka Ya When Chen, Wen Tina Chen, Tina Dunbar, and Tina Dubner — is the owner of Top One Zone, LLC, a company exporting electronic and computer components that Chen operates from her residence. As alleged, from about November 2015 to May 2019, Chen conspired with others to buy and export goods from companies in the United States, and then send those goods to individuals in Iran through companies in Hong Kong. Chen concealed the identities of the end users, and she did not have a license from OFAC. Chen is charged with one count of conspiracy to unlawfully export goods to Iran.
According to the allegations in the indictment, Chen engaged in numerous overt acts of conspiracy including:
Between a Rock and a Hard Place – Conflicting U.S. & EU Sanctions Policies Towards Iran
Background on U.S. Sanctions Programs
The U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) administers a number of different sanctions programs. The purpose of U.S. sanctions programs is to advance U.S. foreign policy objectives and protect national security. Currently, OFAC administers 35 sanctions programs. These sanctions programs vary widely – some are comprehensive while others are highly selective.
OFAC Sanctions & Licensing
Background on U.S. Sanctions (as of May, 2021)
The U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) administers a number of different sanctions programs. The purpose of U.S. sanctions programs is to advance U.S. foreign policy objectives and protect national security. Currently, OFAC administers 35 sanctions programs. These sanctions programs vary widely – some are comprehensive while others are highly selective.
The CAPTA List – An Introduction
What’s the CAPTA List?
The Correspondent Account or Payable-Through Account Sanctions List (“CAPTA” List”) is a list maintained by the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”). The CAPTA List identifies foreign financial institutions that are prohibited or in some way restricted from maintaining a correspondent account or a payable-through account in the United States.
Commerce Department Issues Rule Securing Digital Supply Chains Against Foreign Adversaries
Background on Securing Information Technology & Communications Supply Chains
Treasury Imposes Further Sanctions on Iran
Background on Iran Sanctions
The United States has imposed restrictions on activities with Iran under various legal authorities since 1979, following the seizure of the U.S. Embassy in Tehran following the Iranian Revolution. In October 2015, the United States, the United Kingdom, France, China, and Russia, as well as Germany (known collectively as the P5 +1) met with Iran and successfully negotiated the Joint Comprehensive Plan of Action (“JCPOA”). Pursuant to the JCPOA, Iran agreed to roll back parts of its nuclear program in exchange for relief from some sanctions. According to United Nations Security Council Resolution 2231, the JCPOA would result in “the comprehensive lifting of all UN Security Council sanctions as well as multilateral and national sanctions related to Iran’s nuclear program, including steps on access in areas of trade, technology, finance, and energy.” The few years of decreased economic sanctions towards Iran came to an end in May 2018 when the Trump administration unilaterally withdrew from the JCPOA. The return of increased U.S. sanctions towards Iran came into effect in November 2018.
Ready to Travel to Cuba? OFAC Simplifies Process
Want to travel to Cuba? Well, on April 18, 2013, the Office of Foreign Assets Control ("OFAC") announced its effort to streamline license processing. Read on to see if your able to partake in OFAC's new electronic filing system.
Maersk Pays $3 Million for Trading With Iran and Sudan
Maerk Line, Ltd. paid the U.S. Office of Foreign Assets Control (OFAC) $3 million to settle allegations of violations of the U.S. trade embargo with Sudan and Iran that Maersk committed between 2003 and 2007. How the world's largest ocean transportation company committed such violations is a good story. How Maersk's lawyer was able to limit the payment to $3 million is also important to understand.