The OverRuled: BIS Export Controls Module has been updated with the following actions:
- 06 Dec 2024 - Siberian Airlines - Denial Order; No monetary penalty
On December 6, 2024, BIS renewed against Siberian Airlines (“Respondent”) a Temporary Denial Order (“TDO”) originally issued on June 24, 2022, for a period of one year in relation to violations of the Export Administration Regulations (“EAR”). Specifically, Respondent was involved in operating multiple ECCN 9A991.b aircraft on flights into Russia after March 2, 2022, from destinations including Kazakhstan, Kyrgyzstan, Uzbekistan, China, Thailand, Tajikistan, and Turkey without the required BIS authorization. Further evidence indicated that Respondent operated aircraft subject to the EAR on domestic flights within Russia. The continued operation of these aircraft by Respondent, even on domestic routes within Russia, presents a high likelihood of imminent violations warranting imposition of a TDO. Since that time, BIS has continued to determine that Respondent has engaged in a pattern of repeated, ongoing and/or continuous apparent violations of the EAR. Therefore, renewal of the TDO is necessary in the public interest to prevent an imminent violation.
- 06 Dec 2024 - Nordwind Airlines - Denial Order; No monetary penalty
On December 6, 2024, BIS renewed against Nordwind Airlines (“Respondent”) a Temporary Denial Order (“TDO”) originally issued on June 24, 2022, for a period of one year in relation to violations of the Export Administration Regulations (“EAR”). Specifically, Respondent was involved in operating multiple ECCN 9A991.b aircraft on flights into and out of Russia after March 2, 2022, from/to destinations including Turkey, Egypt, Tajikistan, Iran and Kyrgyzstan without the required BIS authorization. Further evidence indicated that Respondent operated aircraft subject to the EAR on domestic flights within Russia. The continued operation of these aircraft by Respondent, even on domestic routes within Russia, presents a high likelihood of imminent violations warranting imposition of a TDO. Since that time, BIS has continued to determine that Respondent has engaged in a pattern of repeated, ongoing and/or continuous apparent violations of the EAR. Therefore, renewal of the TDO is necessary in the public interest to prevent an imminent violation.
- 20 Dec 2024 - The Indium Corporation of America - No Denial Order; USD $180,000
On December 20, 2024, BIS issued an order approving a settlement between BIS and the Indium Corporation of America (the “Respondent”) in connection with 11 violations of 15 C.F.R. §§ 764.2(a). Specifically, on 11 occasions between on or about April 14, 2022, through on or about March 31, 2023, Respondent exported through Germany to Russia 11 shipments of EAR99 solder preforms, solder wires, and solder ribbon valued at $96,505.89 without the required license or authorization from BIS. As part of the settlement and order, the Respondent was assessed a civil penalty in the amount of $180,000.00.
- 31 Dec 2024 - Daniel Ray Lane - Denial Order; No monetary penalty
On December 31, 2024, BIS issued against Daniel Ray Lane (“Respondent”) a Denial Order for a period of 10 years in relation to violations of 18 U.S.C. § 371 and 50 U.S.C. § 1701. The Order went into effect on Respondent’s date of conviction on June 11, 2024. Specifically, Respondent was convicted of conspiring to sell sanctioned Iranian petroleum/crude oil to a refinery in China. BIS did not impose any monetary penalty.
- 31 Dec 2024 - Derby Clerfe - Denial Order; No monetary penalty
On December 31, 2024, BIS issued against Derby Clerfe (“Respondent”) a Denial Order for a period of 2 years in relation to violations of 18 U.S.C. § 371. The Order went into effect on Respondent’s date of conviction on May 30, 2024. Specifically, Respondent pled guilty to conspiring with others to export from the United States to Haiti nine handguns without the required licenses and without filing Electronic Export Information in the Automated Export System. BIS did not impose any monetary penalty.
- 31 Dec 2024 - Eric Nana Kofi Ampong-Coker - Denial Order; No monetary penalty
On December 31, 2024, BIS issued against Eric Nana Kofi Ampong-Coker (“Respondent”) a Denial Order for a period of 10 years in relation to violations of 50 U.S.C. § 4819. The Order went into effect on Respondent’s date of conviction on September 6, 2023. Specifically, Respondent was convicted of knowingly and willfully attempting to export one SCCY Industries LL.C., Model CPX-2 9mm handgun; one Mossberg 9mm handgun; one Smith & Wesson 9mm handgun; one FIS Product, Model XD-9 9mm handgun; and one Sarsilmaz (Sar Arms) 9mm handgun, which are weapons designated under ECCN 0A501, from the United States to Ghana without the required licenses. BIS did not impose any monetary penalty.
- 31 Dec 2024 - Joel Alejandro Garza-Corona - Denial Order; No monetary penalty
On December 31, 2024, BIS issued against Joel Alejandro Garza-Corona (“Respondent”) a Denial Order for a period of 8 years in relation to violations of 18 U.S.C. § 554(a). The Order went into effect on Respondent’s date of conviction on February 16, 2023. Specifically, Respondent was convicted of smuggling 2,399 rounds of assorted ammunition from the United States to Mexico without the required authorization from the U.S. Department of Commerce. BIS did not impose any monetary penalty.
The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 31 Dec 2024 (OFAC):
The Akin Summary document has now been posted for this action.
The U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") designated the Center for Geopolitical Expertise ("CGE"), a Russian-registered non-profit, and a CGE Director, Valery Mikhaylovich Korovin, pursuant to Russia-related Executive Orders ("E.O.") 14024 and 13848, due to their use of artificial intelligence tools to interfere in the 2024 U.S. election.
- 27 Dec 2024 (OFAC):
The Akin Summary document has now been posted for this action.
The U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") designated Georgian Dream Founder, Bidzina Ivanishvili, pursuant to Russia-related Executive Order ("E.O.") 14024. Concurrent with this designation, OFAC issued a new Russia-related General License (GL 116) that authorizes transactions involving entities blocked as a result of the Ivanishvili designation. OFAC also published one new FAQ (FAQ 1204) clarifying the scope and effect of the GL, authorizing transactions involving entities owned by Ivanishvili (but not Ivanishvili himself).
- 18 Dec 2024 (OFAC):
The Akin Summary document has now been posted for this action.
The U.S. Department of the Treasury’s Office of Foreign Assets Control ("OFAC") designated one individual and three entities pursuant to Russia-related Executive Order ("E.O.") 14024.
Concurrent with these designations, OFAC issued two new Russia-related General Licenses ("GLs") that authorize certain activities involving the Federal State Budgetary Institution Marine Rescue Service (GL 1B) and certain transactions related to civil nuclear energy involving Gazprombank (GL 115). OFAC also published one new FAQ clarifying the scope and effect of the GL for Gazprombank transactions related to civil nuclear energy (FAQ 1203), and issued an amended FAQ clarifying the scope and effect of the GL for certain activities involving the Federal State Budgetary Institution Marine Rescue Service (FAQ 894).
- 16 Dec 2024 (OFAC):
The Akin Summary document has now been posted for this action.
The U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") designated nine individuals and seven entities pursuant to Russia-related Executive Order ("E.O.") 14024 and North Korea-related E.O.s 13382, 13551, 13687, and 13810, targeting the provision of financial and military support to the Democratic People's Republic of Korea ("DPRK") and its deepening military support for Russia.
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