U.S. Commerce Department Adds Nine Persons Associated with Missile Proliferator to Entity List

The BIS at the U.S. Department of Commerce in late April 2014 added one Chinese individual and eight Chinese companies to the BIS Entity List in connection with their affiliation with Chinese weapons proliferator Li Fangwei in efforts to supply Iran’s ballistic missile program. To designate persons for the Entity List, the U.S. government must determine that listed persons are acting against U.S. national security or foreign policy interests. In a related action, the U.S. Department of the Treasury (the “Treasury Department”) sanctioned the eight Chinese companies. Read the BIS press release and the Treasury Department press release for more details.

Amendments to Iranian Transactions and Sanctions Regulations

OFAC adopted a final rule in early April 2014 that amends the ITSR to expand the general license authorizing food exports/reexports to persons in Iran by including the more broadly defined category of agricultural commodities, with certain exclusions, and to clarify that eligible items are both items that are subject to the Export Administration Regulations (EAR) and classified as EAR99 and items that are not subject to the EAR but would be classified as EAR99 if subject. The amendment also creates a new general license for the export/reexport of designated replacement parts for certain medical devices. Read the Treasury Department’s announcement and the final rule and background information in the Federal Register.

Issuance of South Sudan-related Executive Order and Designation

President Barack Obama issued an Executive Order in early April 2014 permitting sanctions against individuals and entities responsible for the conflict in South Sudan and who threaten the peace, stability and security of South Sudan. OFAC responded in early May by adding certain South Sudan-connected individuals to its SDN List. Read the Executive Order, the OFAC designations and the Treasury Department coverage.

OFAC Releases Ukraine-Related Sanctions Regulations

On May 8, 2014, OFAC released regulations pursuant to President Obama’s March 2014 Ukraine-related Executive Orders. The new Ukraine-Related Sanctions Regulations include provisions detailing prohibited transactions, as well as provisions on licenses under the OFAC-administered sanctions regime. OFAC intends to further supplement the regulations to include “additional interpretative and definitional guidance and additional general license and statements of licensing policy.” Read the new regulations and Treasury Department coverage.

Interim Final Rule Transitions Certain Spacecraft Items to the Commerce Control List

BIS issued an interim final rule in mid-May 2014 relating to the export jurisdiction of certain spacecraft and related items. The rule, part of President Obama’s Export Control Reform Initiative, creates new Export Control Classification Numbers (ECCNs) on the Commerce Control List under the EAR, which, along with certain existing ECCNs, will control certain spacecraft and related items deemed to no longer warrant control under the U.S. Munitions List and the International Traffic in Arms Regulations. The Departments of State and Commerce have requested comments on the interim final rule, given the national and economic security implications of the rule. Read the interim final rule summary and comments.