We all watched the events of these past weeks in Afghanistan take place in rapid succession. Then Sunday, the Taliban overran the roughly 20-year old, U.S.-supported government last headed by Ashraf Ghani, forcing him into exile. While U.S. contractors have largely left the country, it is still noteworthy that Afghanistan is now ruled by an OFAC-designated group. This makes virtually all interactions with the new leaders in Kabul prohibited (well, dealings with the Taliban have been prohibited for quite a long time, but now they run the country).
Specifically, the Taliban is designated by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) under the Global Terrorism Sanctions Regulations, 31 CFR Part 594 (the “GTSR”). This means that they are on OFAC’s list of Specially Designated Nationals and Blocked Persons (the “SDN List”, sometimes called the OFAC “blacklist”).
Dealings with such parties by U.S. persons (i.e., U.S. citizens and permanent residents wherever they reside, and U.S. companies or companies owned by them) are almost entirely prohibited, with very limited exception. This covers the importation and exportation of goods and services (which can include matters like receiving permits to operate on the ground in Afghanistan, etc.), and other issues. This means that a lot of dealings with Afghanistan’s government that did not require OFAC licensing effectively now do. Naturally, it can have tremendous effects on media, non-governmental organizations working in Afghanistan, and other charitable providers, as well as on even non-U.S. parties such as banks, money remitters, etc.
Given the freshness of these events, OFAC might not have had the chance to issue new regulations, guidance, and or clarifications on this issue, but don’t be surprised if it does in the coming days (Reuters reported today that the UK has indicated new sanctions). Also note that a number of other entities in Afghanistan are SDGTs.
This isn’t the first time a country is headed by a U.S. sanctioned-party – Iran’s new president Ebrahim Raissi is himself an SDN, and many members of Iran’s regime are SDNs. Similarly Bashar Assad of Syria and some in his government are also sanctioned by OFAC.
The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a settlement yesterday with a U.S.-based company Alfa Laval Inc. (“Alfa Laval U.S.”) and a Dubai-based affiliate company Alfa Laval Middle East Ltd. (“Alfa Laval Middle East”) today over potential civil charges for conspiracy to ship goods to the U.S. goods to Iran and facilitating a transaction to ship U.S. goods to Iran, respectively.
Alfa Laval U.S., based in Richmond, is a subsidiary of Alfa Laval AB, a Swedish-based company that exports storage tank cleaning units worldwide. The U.S. operation has a subsidiary company in Exton, Pennsylvania called Al Laval Tank, Inc. (“Alfa Laval Tank”), which was the subject of this action. In 2015, Alfa-Laval Tank received an email from Alborz Pakhsh Parnia Company, an Iranian party requesting a shipment of cleaning products to Iran. A representative of Alfa Laval Tank provided pricing and other information, and then forwarded the communication to an affiliate operation in Denmark, which then referred the matter to Alfa Laval Middle East, the UAE-based sister company. Those of you who know your sanctions laws may immediately think this is a prohibited facilitation under the Iranian Transactions and Sanctions Regulations, 31 CFR Part 560 (the “ITSR”), as it is, even if it is a bit more tenuous than a text-book facilitation case. However, there’s more.
As Alfa Laval Middle East and the Iranian customer devised a plan by which AL Middle East would ship U.S. goods to the Iranian customer, it copied the U.S.-based Alfa Laval Tank on the emails. Working with Alfa Laval AB’s Iran operations, Alfa Laval Middle East and the Iranian customer formed a conspiracy to commit sanctions violations, drawing in part on a memo provided by Alborz on how to route the transactions to make them appear to be shipments destined for Dubai end use. They did not include Alfa Laval Tank on any emails that stated they planned to commit sanctions violations. They did, however include Alfa Laval Tank on an email with a subject line “Gamajet for [Iranian customer’s name],” with Gamajet as the name of the cleaning product to be shipped. As a result, Alfa Laval could have been penalized for not only facilitating a transaction that would have been prohibited if performed by a U.S. person under the ITSR but for basically indirectly exporting to Iran as it failed to heed or largely ignored several warning signs that its goods were at risk of diversion to Iran.
OFAC deemed the Alfa Laval U.S.’s failure on behalf of its subsidiary a non-egregious violation of the ITSR, resulting in a $18,750 penalty from OFAC. The ultimately settled amount of $16,875 with OFAC reflects various aggravating and mitigating factors listed here. The Dubai company that settled with OFAC, Alfa Laval Middle East, is a subsidiary of Alfa Laval AB and faced a penalty for conspiracy and completion of sanctions violations under the ITSR. After Alfa Laval Middle East received an email from AL Tank referring an Iranian customer that wanted a shipment from Alfa Laval Tank, the Dubai-based operation fabricated a conspiracy by which Alfa Laval Tank would unwittingly ship U.S. goods to Iran. The plan, concocted with the Iranian customer, entailed listing a Dubai distributor with whom Alfa Laval Middle East did business as the end-user for the shipment from Alfa Laval Tank on its export forms. It did not tell Alfa Laval Tank that it had falsified the end-user on export forms. When Alfa Laval Tank shipped items to the “Dubai-based company,” Alfa Laval Middle East arranged for the items to, in fact, go to the customer in Iran. It ultimately enabled the shipment of $18,585 of U.S. goods to Iran and Alborz sought products to the tune of $181,453 in totality. For this conspiracy and commission of sanctions violations, Alfa Laval Middle East faced a penalty of $615,844 from OFAC. Its large settlement amount of $415,695 is the result of not just aggravating factors, but also significant mitigating factors.
Interestingly, this case ensued from a U.S. Department of Commerce Bureau of Industry & Security (BIS) Post-Shipment Verification of Alfa Laval Tank’s shipment to Dubai, with the verification concluding that the items had been reshipped from Dubai to Iran. The size of the penalty against the Dubai company is significant as it, like cases before it, drives home the substantial liability non-U.S. companies are exposed to for U.S. sanctions violations, and the magnitude of the penalties that could arise from a fairly modest shipment value – less than $18,600 here.
The U.S. Department of Commerce’s Bureau of Industry & Security today issued a Final Rule, published in the Federal Register, adding four Burmese companies onto its Entity List. This move was in furtherance of Executive Order 14014 (February 12, 2021), which was issued by the Biden Administration following the Burmese military’s February 1, 2021 coup in that country.
Specifically, the following entities were listed:
King Royal Technologies Co., Ltd.;
Myanmar Wanbao Mining Copper, Ltd.;
Myanmar Yang Tse Copper, Ltd.; and
Wanbao Mining, Ltd.
The first company is a telecommunications entity alleged to provide support for the Burmese military. The second and third entities are subsidiaries of Wanbao Mining, Ltd., the fourth entity (note that BIS designations on the Entity List apply only to the named company, and as such, subsidiaries are not considered listed by default unless they are actually named on the list). These three entities are active in Burma’s copper mining sector.
The limitations on these four entities is the strictest type seen on the Entity List – a license is needed for any item subject to the Export Administration Regulations (EAR) if destined for any of these four entities, with a presumption of denial for any applications.
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) today announced it was imposing a $4.1 million penalty against Nebraska-based Berkshire Hathaway Inc. for illicit transactions by its Turkish subsidiary Iscar Kesici Takim Ticareti ve Imalati Limited Sirket (“Iscar Turkey”) with Iran. While announcements of OFAC penalties for sanctions violations are not rare, this one has a few notable points.
At first glance, the fact pattern is not terribly uncommon. A Middle Eastern subsidiary of a U.S. company engaged in illicit trade with Iran. Oftentimes this comes from misunderstanding by local managers and employees. This time, the knowledge was there, as were clear warnings coming from the home base not to violate sanctions. According to the OFAC Settlement Agreement, Iscar Turkey is in the business of manufacturing machinery, specifically cutting tools and inserts. Its local manager thought EU and US sanctions on Iran would ultimately be lifted, and to prepare for this, began low level trade with Iran using Euro payments and falsified invoices from Turkish companies (to hide that the shipments were going to Iran). This was coupled with other actions, including travel to Iran. In all, 144 transactions were consummated with Iran, with the transaction value totaling $383,443.
So what are the takeaways? Here are just a few.
Transaction Value versus Penalty Amount. $383,443 is roughly 9% of the final penalty amount settled with OFAC – $4,144,651. But it would be foolish to look at the penalty alone. Think of the legal fees and the cost of the internal review just to start – a lot of work likely went into this response and reaching this settlement. That is not cheap and beyond financial cost, probably resulted in many lost hours at the company directed towards the internal review and back and forth with counsel and compliance experts. Notably, this case arose from a Voluntary Self-Disclosure (VSD), which means the maximum penalty amount was already reduced by 50% (OFAC encourages such disclosures by offering up a 50% discount, with other factors potentially also helping bring down the penalty amount). In other words, penalties could have been much higher had OFAC learned about this on its own without the VSD. OFAC itself mentions the base civil penalty amount was $18,420,672 – meaning Berkshire’s pro-active response and the existing facts caused a 77%+ reduction in potential penalties.
Hefty Settlement Covenants. Remedial steps are critical in mitigating penalties in an apparent violation. The steps Berkshire agreed to here are fairly rigorous. There are specific mentions in the Settlement Agreement of management commitment, imposing strict internal controls, better training, risk assessment, and testing and auditing. These are all fairly standard steps a company in such a position should take, but the granularity of the covenants in the Settlement Agreements highlights their importance.
Berkshire had taken some precautions. Oftentimes fines can come from pure recklessness from the top down, but this does not really seem to be the case here. Per the Settlement Agreement “The Apparent Violations occurred under the direction of certain Iscar Turkey senior managers despite Berkshire and IMC’s repeated communications to Iscar Turkey regarding U.S. sanctions against Iran and the application of the ITSR to Iscar Turkey’s operations.”
Like many cases before it, but in some ways more so, the lesson learned here is that the discovery of violations merit serious responses. While Iscar Turkey was the downstream subsidiary of a major, public U.S. corporation, it is still a foreign company. The transactions were not huge in value, and arguably not even a footnote for a company of Berkshire’s scale. Therefore, seeing this, one can imagine what the stakes could be for sanctions violations by U.S. persons in the United States.
Importantly, companies sometimes simply do no take these violations seriously. Maybe it’s due to their personal beliefs (e.g., opposition to sanctions, thinking the sale bears no impact on U.S. policy) or the fact that OFAC is still a civil agency and such cases often do not have a criminal enforcement angle. This can be disastrous for several reasons – it prevents a serious response which can mitigate the penalty as well as reduce the likelihood of future violations, and it also prevents learning a lesson (perhaps unless OFAC responds by coming down with a hefty penalty). While it should go without saying, not committing to serious compliance approaches can be damaging and can lead to violations. Not taking serious approaches can be far worse. Based on what is provided in the Settlement Agreement, Berkshire’s remedial approach appears to have likely been fairly solid.
The lessons learned here are broad and go far beyond Iran sanctions, which were far narrower in scale in 2012-2016 when the violations occurred in this case. They tell us a lot about the agency’s approaches, and perhaps unaffected by who will be sitting in the White House on January 20, 2021. As such, those thinking a potential Biden win could cause sanctions to reverse course should look at examples like this – Obama-era violations, and take note.
In an interesting OFAC Enforcement Release issued this week, the agency announced that an individual formerly working for the U.S. Army was fined for engaging in transactions with a foreign person designated as a Specially Designated National (SDN).
Specifically, a U.S. Army official stationed at the U.S. Embassy in Colombia was penalized for engaging in at least 24 transactions with a narcotrafficker designated by OFAC. The U.S. person stationed in Bogota had evidently befriended an individual that has been designated by OFAC, and had over time “bought jewelry, meals, clothing, hotel rooms, and other gifts” for the individual over the course of a relationship. Ultimately the penalty was reduced from a maximum of over $33 million down to $5,000. While the penalty amount is not anything drastic and certainly far below the massive penalties we often see in OFAC enforcement cases against companies, this case is very interesting on a number of fronts – including the fact that:
(1) such releases seem to rarely be issued against natural persons;
(2) there was no identifying information of any of the parties (compared to corporate enforcement releases where the names of companies are generally provided); but also
(3) because of the nature of the transactions at issue – these were not commercial transactions per se but rather appear to have been the hallmarks of a personal relationship – gifts, meals, hotel stays. It begs the question – are personal relationships and generally friendships subject to sanctions?
For those who are familiar with sanctions laws, the answer is pretty clear. When parties are designated by OFAC, depending on the program under which they are sanctioned, most transactions with them by U.S. persons become prohibited for the U.S. person. Given the bar on dealings in the transfer of property to/from such parties, there is no line drawn for individual relationships. In other words, just like a U.S. person generally cannot export goods to a sanctioned company, it would naturally follow that they cannot give a gift to a sanctioned individual, or say, receive money or a small loan from that person. Again, the limitations vary based on the program under which the party is sanctioned, but these kind of limitations are not uncommon, regardless of the country the party is in.
There are a few key takeaways here, but it appears the biggest is the fact that sanctions laws like so-called “blocking programs,” whereby individuals and organizations are subject to blocking by U.S. persons (think of narcotraffickers, kingpins, certain terrorist entities, persons designated for corruption or human rights violations, etc.) are not just limited to corporate entities and are generally comprehensive enough to have an impact on personal relationships.
Further, the case very importantly highlights that compliance is critical for individuals too. This can translate into many different contexts – individual transactions in sanctioned countries like Iran or Cuba for example, or personal dealings (e.g., gift giving) with parties on the SDN list that may not fit many people’s definition of “commercial.” While all interaction with such a party might not be prohibited, they can still be under strict limitations, and the law often does not distinguish between “arms-length” commercial transactions or activities (like gift giving) that may transpire in the course of a personal relationship. As such, individuals should be alert to these risks and work to prevent them accordingly.
On July 1, the U.S. Departments of State, the Treasury, Commerce, and Homeland Security issued a detailed advisory. This is in response to the various types of regulatory exposure companies could face when dealing with suppliers and vendors in China’s northwestern Xinjiang region, given substantial allegations of forced labor and other human rights abuses.
The focus of the Advisory is on what the government identifies as the three key risk factors:
Assistance in the transfer of surveillance technology to the Chinese government.
Relying on labor sourced to the Xinjiang region, which may be among other things, forced.
Aid in the construction of internment facilities for various minorities, such as the Uyghurs and other Muslim minority groups, including the Kazakhs.
The issues cited by the July 1 Advisory have various potential applications under U.S. trade law, including sanctions and export controls. A number of Chinese companies and government entities have in recent months been added to the Department of Commerce’s Bureau of Industry & Security (BIS) Entity List.
According to the Advisory, broad swaths of sectors are affected by the issue of forced labor, from mobile phones to cleaning supplies, food processing, and textiles, among many others.
The advisory also touches on a number of other compliance-based issues for a broad range of businesses, including financial institutions.
What’s the takeaway?
The obvious lesson here is that the Xinjiang region has certain risks for U.S. companies, both legally and reputationally. However, there are two other issues here:
Region-specific risks. In some ways Xinjiang highlight risks in the Advisory are like geographic compliance risks in other regions, for example in the Middle East (regarding Syria, Iran, Russia) or Latin America (Cuba and Venezuela).
The drive towards more sophisticated risk-based, detailed compliance programs. Over the years it has been made increasingly clear that compliance programs are not “check the box” exercises and government enforcement agencies are giving these programs increasing scrutiny in order to assess their efficacy. Laws change, and so do risks. Accordingly, it makes sense to incorporate measures to protect against evolving risks like those detailed in the Advisory. These changes will help prevent dynamic risks like those related to sourcing and dealing in Xinjiang. Add to this the increasing number of risk advisories issued by agencies like OFAC, and it becomes clearer that periodic evaluation and assessment is critical.
Companies doing business in Xinjiang or with vendors from the region should take note and dig deeper beyond the advisory, understanding the particular risks of their respective sectors, and with their specific counterparties.
The U.S. Department of Commerce’s Bureau of Industry & Security (BIS) yesterday granted an extension of the existing Temporary General License (TGL) for China’s Huawei Technologies Co. and 115 other affiliates around the world from those parties’ current placement on the BIS Entity List.
A previous TGL (modifying the respective Entity List entries) was issued on May 20, 2019 for the original 69 entities placed on the list, and a subsequent extension incorporating the additional 46 entities was issued on August 21, 2019 (effective August 19).
The extension of the TGL provides these entities with some significant reprieve, however it does not remove their entries from the Entity List. As this reprieve is not permanent and is subject to repeal, and as it does not cause a removal from the Entity List for that period of time, there are still lingering effects that likely cause hesitation for many companies considering business with Huawei, including those whose products and technologies are not of U.S. origin or otherwise subject to the U.S. Export Administration Regulations (EAR).
The timely nature of these TGLs reflects in some part the urgency given the widespread use of Huawei’s technologies and products. Other companies named to the Entity List may experience a tougher challenge in demonstrating the need for such relief, and the presumption is likely that the named party is actively seeking permanent removal from the list, not just a series of short-term lifelines. This requires a good-faith effort to take all steps required to seek a proper delisting of the company.
While many professionals in the compliance space around the world are familiar with the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) list of Specially Designated Nationals and Blocked Persons (the “SDN List”), another U.S. government list is quickly rising in importance. As news articles over the past few years (think ZTE and Huawei) have indicated the U.S. Department of Commerce’s Bureau of Industry & Security’s Entity List is becoming increasingly noticed and used as a tool of U.S. foreign policy in curtailing the flow of U.S. origin goods and technologies to certain foreign parties.
The Entity List is arguably the most potent list at the BIS, an agency tasked with administering the Export Administration Regulations (“EAR”), a set of regulations governing U.S. origin goods – broadly defined in a way that covers many goods made even outside the United States with U.S. technologies or foreign goods that have transited through the United States. While a BIS list, the naming of parties to the Entity List, the modification of their entries, and their removal is the responsibility of the End-User Removal Committee (ERC), an inter-agency group with representatives from various U.S. departments, including Commerce, Defense, and Energy.
The impact of being on the Entity List can be devastating. The limitations can vary, for example some Russian entities on the list are subject to somewhat narrow prohibitions on certain oil extraction-related technologies (which can be very broad for their purposes given the scope of what they do) to blanket bans on all items subject to the EAR. It usually leads to a domino effect, where even transactions that are not prohibited become impossible to execute due to de-risking by suppliers, vendors, and service providers like banks and shippers, in cases where the transaction is not even prohibited under the regulations. Broad prohibitions can be painful and can cause companies to collapse. You may recall a story where China’s ZTE was apparently unable to fix a urinal in its men’s room due to difficulty in obtaining a part, all arising from its Entity List designation.
Removal from the Entity List, while rare, is not impossible. The rarity may come from the fact that few may take the necessary expert approach towards removal. It’s critical to take immediate steps quickly to begin the process for permanent removal, and this should be done by experienced lawyers well-versed in U.S. trade regulations, particularly export controls. Given the reputation issues at stake, companies that are serious about rehabilitating their businesses must address the designation seriously.
The US Department of the Treasury announced it was adding scores of Iranian entities to its list of Specially Designated Nationals and Blocked Persons (the SDN list) due to their connections with the Islamic Revolutionary Guards Corps (IRGC)-affiliated Basij force, specifically the Bonyad Taavon Basij (Basij Cooperative Foundation). Importantly, however, these additions are not strictly military related, and include some Iranian economic giants across sectors including automotive, finance, and mining, including household names such as:
Bahman Automotive Group
Esfahan Mobarakeh Steel Company
Iran Tractor Manufacturing Company (ITMC)
Mehr Eqtesad Bank
Mobarakeh Steel and ITMC are the largest companies in the region in their respective sectors of steel production and tractor manufacturing. Importantly, Bank Mellat and Bank Parsian are among Iran’s largest financial institutions. Bahman Group is a large automotive company that has assembled foreign automobiles in Iran.
The additions of the banks may be the most interesting for many, especially U.S. persons seeking to divest from Iran. Being designated under the SDGT (Executive Order 13224) makes virtually all transactions with such entities prohibited. This covers otherwise exempt or general license transactions such as medical, food, and agricultural sales, and the transfer of personal remittances. As such, to the extent U.S. persons have any transactions with Iran in non-sanctioned areas such as humanitarian sales and divestment or personal remittances, they should take extra care to make sure such entities have no interest in such transactions. Any such involvement can subject such funds to blocking upon coming into possession of a U.S. person. The release of blocked funds requires a specific OFAC license. If such entities have been or are involved, a specific OFAC license will now be needed and such parties should not proceed without first consulting a professional.
This announcement dovetails an advisory issued last week by the Department of the Treasury’s Financial Crime Enforcement Network (FinCen) on deceptive Iranian financial practices.
Importantly, today’s move by the Department of the Treasury does not appear to be related to President Trump’s announcement in May 2018 that the United States would be ceasing participation in the Joint Comprehensive Plan of Action (the “Iran Deal”), but rather part of the Administration’s policy to increase pressure against the Islamic Republic, particularly on the economic front.
We’ve been getting a lot of questions at the office as to what President Trump’s May 8, 2018 announcement to cease U.S. participation in the Joint Comprehensive Plan of Action (JCPOA, also known as the “Iran Deal”), an agreement between Iran and the “P5+1” (U.S., UK, France, Russia, China, and Germany) over Iran’s nuclear program. In the midst of this sanctions snap-back and sliding value of the Iranian Rial, many Iranian-Americans naturally have some cause for consternation and confusion.
Importantly, the general laws on remittances and asset divestiture from Iran are largely the same for U.S. persons, which the sanctions regulations define as U.S. citizens and permanent residents wherever they are (including in Iran) or other people physically in the United States. While we can no longer import Iranian-origin food products or carpets, regulations governing the sale of personal assets, the transfer of personal and family funds and the receipt of gifts remain intact. The only noticeable difference legally is that certain Iranian banks like Melli, Mellat, Sepah, and Tejarat will soon return to the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) list of Specially Designated Nationals and Blocked Persons (the “SDN” list). This means that transactions involving such entities will largely require specific OFAC licenses to be permissible to avoid blocking (aka “freezing”) by U.S. banks, for example.
Beyond the law however, we are seeing some tangible differences from the pre-JCPOA era. For one, the size of transfers appears to be shrinking, although this may be a direct result of the spike in the Dollar’s value versus the Iranian Rial/Toman. In other words, for example, a $500,000 asset divestiture may require more funds transfers now than before.
Also, banks appear to be stepping up scrutiny of Iran-related transfers (such as gifts, proceeds from the sale of real estate, etc.) Remember, the law does require you to keep proper records of Iran-related transactions and these laws are not new. However, recent trends we have seen point to the increased importance of this. It is not only a legal requirement but a best practice that banks will likely look for more and more when processing funds transfers for their clients.
The best you can do is be firm on what the law is – often many people start inquiring as to what U.S. law is after they have begun the divestment or transfer process. That’s too late. Many transactions require licenses and while the laws on such licensing haven’t changed because of the JCPOA (other than issues connected to banks that will go back on the SDN list and an increased number of other entities that are being designated by OFAC), the logistics are getting a bit more difficult. These logistical issues can naturally create legal exposure points, so it’s best to be thorough and comprehensive. Exercising best practices is not only a matter of complying with the law but keeping good documents and properly informing your U.S. financial institution through the right channels (i.e., informing the right people, not just anybody at the bank).
Remember, banks often look for erratic activity in accounts, much like credit card companies do. Oftentimes remittance transfers from Iran (like the transfer of inheritance or the sale of a home) will be unlike transactions typical to your account, and the source is not going to be identifiable as funds must be processed from a third country. This can arouse suspicion for a completely lawful transfer. Therefore, as bank compliance departments increase their scrutiny, there will be more responsibility on the part of customers to ensure that the underlying transaction (1) was lawful, and either allowed by OFAC by general or specific license (and you have a specific license if needed); and that (2) all aspects of the handling and transfer of the funds are lawful. Otherwise you can run a high risk of having your funds rejected, or your account. It is key to provide proper documentation to your bank’s compliance team to ensure everything is not only done legally but also transparently.
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