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Obligations of Foreign-based Persons to Comply with U.S. Sanctions and Export Control Laws

The U.S. Department of Justice, the U.S. Department of Commerce, and the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), issued a Tri-Seal Compliance Note: “Obligations of Foreign-based Persons to Comply with U.S. Sanctions and Export Control Laws” today providing guidance regarding the ability of the U.S. government to hold both U.S. and non-U.S. persons and companies accountable for violations of U.S. sanctions and export control laws., click here.

Penalty Issued for Israeli Antiboycott Requests from Pakistan

A Pennsylvania-based company was issued a penalty of $153,175.00 from the Bureau of Industry and Security for failing to report 43 requests from its Pakistani customer to not provide Israeli-origin products. While boycott-related requests of Israeli products are usually received from Arab League countries, the Export Administration Regulations prohibiting compliance with, and requiring the reporting of these requests are not limited to any one country or region., click here.

OFAC Settles with Privilege Underwriters Reciprocal Exchange for $466,200 for Apparent Violations of the Ukraine-/Russia-Related Sanctions Regulations

Privilege Underwriters Reciprocal Exchange (PURE), an insurance organization based in White Plains, New York, has agreed to pay $466,200 to settle its potential civil liability for 39 apparent violations of Office of Foreign Assets Control (OFAC’s) Ukraine-/Russia-Related sanctions. Between May 2018 and July 2020, PURE engaged in transactions related to four insurance policies involving a blocked Panama-based company (Medallion, Inc.) owned by Specially Designated National Viktor Vekselberg (Vekselberg). Despite being provided with this company’s ownership information in 2010, PURE paid a $7,500 claim and provided insurance coverage and collected 38 premium payments totaling $308,390 for Vekselberg’s property for more than two years. , click here.

U.S. Treasury Identifies $1 Billion Worth of Transactions Suspected of Possible Evasion of Russia-Related Export Controls

In reviewing Bank Secrecy Act filings, the Financial Crimes Enforcement Network of the U.S. Department of Treasury identified up to a $1 billion worth of transactions that could have evaded Russia-related export controls and sanctions between 2016 and 2022. Financial institutions that submitted the Bank Secrecy Act reports flagged the transactions as being suspicious based on its review of the transaction information, bills of lading, invoices, and additional research conducted., click here.

Mexico Implements Increased Duties of up to 25% on Certain Products

Mexico is imposing temporary duties between 5% and 25% on almost 600 tariff classifications for products originating from countries with which it does not have a free trade or preferential agreement. The decree and list of impacted tariff classifications may be found at the link provided, click here.
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