New Updates for 06-Nov-2024

2024-11-06

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The OverRuled: BIS Export Controls Module has been updated with the following actions:

  • 29 Oct 2024 - Mahan Airways; Pejman Mahmood Kosarayanifard; Mahmoud Amini; Kerman Aviation; Sirjanco Trading LLC; Mahan Air General Trading LLC; Mehdi Bahrami; Al Naser Airlines; Ali Abdullah Alhay; Bahar Safwa General Trading; Sky Blue Bird Group; Issam Shammout - Denial Order; No monetary penalty

    On October 29, 2024, BIS renewed against Mahan Airways, Pejman Mahmood Kosarayanifard, Mahmoud Amini, Kerman Aviation, Sirjanco Trading LLC, Mahan Air General Trading LLC, Mehdi Bahrami, Al Naser Airlines, Ali Abdullah Alhay, Bahar Safwa General Trading, Sky Blue Bird Group, and Issam Shammout (“Respondents”) a Temporary Denial Order (“TDO”) originally issued on March 17, 2008, for a period of one year in relation to violations of the Export Administration Regulations (“EAR”). On March 17, 2008, BIS issued an order denying Mahan Airways’, and other denied persons, export privileges for 180 days. The order was issued ex parte pursuant to Section 766.24(a) of the EAR and went into effect on March 21, 2008. This TDO was renewed in accordance with Section 766.24(d) of the EAR. Subsequent renewals also have been issued pursuant to Section 766.24(d), including most recently on October 31, 2023. Some of the renewal orders and the modification orders that have been issued between renewals have added certain parties as respondents or as related persons, or effected the removal of certain parties. The TDO was originally imposed on Respondents because they engaged in the reexport and attempt to reexport of six ECCN 9A991.b U.S.-origin aircraft to Iran without the required licenses. Since that time, BIS has continued to determine that the Respondents have acted in violation of the Regulations and the TDO; that such violations have been significant, deliberate and covert; and that given the foregoing and the nature of the matters under investigation, there is a likelihood of imminent violations. Therefore, renewal of the TDO is necessary in the public interest to prevent imminent violation of the Regulations.

  • 01 Nov 2024 - GlobalFoundries U.S. 2 LLC; GlobalFoundries U.S. Inc - No Denial Order; USD $500,000

    On November 1, 2024, BIS issued an order approving a settlement agreement between BIS and GlobalFoundries U.S. 2 LLC and GlobalFoundries U.S. Inc. (collectively “GlobalFoundries”) for a $500,000 civil monetary penalty in connection with violations of 15 C.F.R. § 764.2(a). Specifically, between, on or about February 16, 2021, and on or about October 26, 2022, Respondent engaged in conduct prohibited by the Export Administration Regulations (the "Regulations") on 74 occasions when it exported without authorization approximately 5,697 silicon wafers--items classified under ECCN 5A991.g or designated EAR99--valued at approximately $17,101,679 to SJ Semiconductor, a company listed on BIS Entity List. GlobalFoundries reported these transactions to BIS in voluntary self-disclosure submissions dated April 8, 2023, and November 30, 2023.

The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:

  • 05 Nov 2024 (UK):

    ​The Office of Financial Sanctions Implementation ("OFSI") updated several of its UK Financial Sanctions FAQs ("FAQs") regarding the new Legal Services General Licence INT 2024/5334756 (the "General Licence").

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