Notably. The BIS order requires Dotphins personnel to attend an export control compliance program within 12 months from the date of the order, and certify that attendance to BIS. The order also imposes a denial of export privileges for two years, though the denial is suspended for a two-year probationary period so long as the company (1) does not commit any additional EAR violations and (2) attends and certifies to attendance at an export control compliance program. This matter is a reminder that even low-value monetary transactions can trigger significant penalties, including when exports are made to relatively low-risk U.S. trading partners.
U.S. Citizen Sentenced to 30 Months in Prison for Conspiring to Provide Electronic Equipment and Technology to the Government of Iran (DOJ Action)
Those involved. Kambiz Attar Kashani, dual citizen of the United States and Iran.
Charges and penalties. Conspiracy to Violate IEEPA (sentenced to 30 months in prison).
What happened? On February 9, Kambiz Attar Kashani was sentenced to 30 months in prison for illegally exporting “six power suppliers, two subscriptions to a proprietary computer software program, several fixed attenuators, two subscriptions to operating software, and several storage systems” to Iranian end users, including the OFAC-designated Central Bank of Iran. Kashani falsely claimed that United Arab Emirates- (UAE) based companies would be end-users to conceal the illegality of the exports. Kashani pleaded guilty in June 2022 and agreed to pay a $50,000 fine.
The DOJ press release can be found here. The indictment can be found here.
Notably. Unsurprisingly, a willful violation of U.S. sanctions can lead to prison time. What is perhaps more useful to take from this action is the fact that Kashani used the UAE either as a transshipment point or simply as a front for shipments to Iran. The UAE and Dubai, in particular, continue to be common jumping-off points for Iran, and thus shipments to the UAE, even when not undertaken intentionally to violate U.S. sanctions, should be carefully screened and monitored.
Iran-Related Additions to OFAC’s SDN List (OFAC Action)
On February 9, OFAC designated nine entities that “have played a critical role in the production, sale, and shipment of hundreds of millions of dollars’ worth of Iranian petrochemicals and petroleum to buyers in Asia.”
The entities are as follows:
Amir Kabir Petrochemical Company
Simorgh Petrochemical Company
Laleh Petrochemical Company
Marun Tadbir Tina Company
Marun Sepehr Ofogh Company
Marun Supplemental Industries Company
Asia Fuel PTE. Ltd.
Sense Shipping and Trading SDN. BHD.
5 International Trade Enforcement Roundup |
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