International Trade Enforcement Roundup | February 2023

Unicious Energy PTE. Ltd.

The OFAC press release can be found here.

On February 3, OFAC designated eight senior directors of Paravar Pars Company, an Iranian manufacturer of drones.

The OFAC press release can be found here.

BIS Orders Denying Export Privileges

BIS orders denying export privileges from criminal convictions pursuant to Section 1760(e) of the ECRA (formerly known as 11h denials): On February 22, Qingshan Li was denied export privileges until June 12, 2030 (10 years from his conviction). Li was convicted of violating Section 38 of the AECA for attempting to export a Harris Falcon III AN/PRC Radio, an item designated as a defense article on the United States Munitions List (USML), from the United States to China without the necessary license. The 1760(e) order can be found here. On February 22, Javier Campos was denied export privileges until February 22, 2031 (10 years from his conviction). Campos was convicted of violating 18 U.S.C. § 554(a) for smuggling and attempting to smuggle 6000 rounds of ammunition from the United States to Mexico. The 1760(e) order can be found here. On February 22, Marco Rodriguez was denied export privileges until March 12, 2031 (10 years from his conviction). Rodriguez was convicted of violating 18 U.S.C. § 371 and 18 U.S.C. § 554(a) for conspiring and illegally smuggling 10,000 rounds of ammunition from the United States to Mexico. The 1760(e) order can be found here. On February 14, Carlos Francisco Rodriguez was denied export privileges until November 3, 2028 (7 years from his conviction). Rodriguez was convicted of violating 18 U.S.C. § 554(a) for attempting to smuggle almost 16,000 rounds of ammunition from the United States to Mexico. The 1760(e) order can be found here. On February 14, Jorge Martin Dorame, Jr. was denied export privileges until January 26, 2026 (5 years from his conviction). Dorame was convicted of violating 18 U.S.C. § 554(a) for smuggling various weapons and weapons components from the United States to Mexico. The 1760(e) order can be found here. On February 14, Rafael Palomares, Jr. was denied export privileges until May 13, 2031 (10 years from his conviction). Palomares was convicted of violating Section 38 of the AECA for agreeing to conspire with others to export various firearms from the United States to Mexico without the required license. The 1760(e) order can be found here. On February 14, Shuren Qin was denied export privileges until September 8, 2031 (10 years from his conviction). Qin was convicted of violating the IEEPA for conspiring to illegally export items from the United States to an entity on Commerce’s Entity List, Northwestern Polytechnic University. Qin was also convicted of making false representations to law enforcement agents and illegally exporting hydrophones to China. The 1760(e) order can be found here. On February 8, Luc Emond was denied export privileges until February 19, 2025 (5 years from his conviction). Emond was convicted of violating 18 U.S.C. § 554(a) for attempting to smuggle two pistol kits from the United States to Canada. The 1760(e) order can be found here. On February 8, Arash Yousefi Jam was denied export privileges until October 14, 2028 (7 years from his conviction). Jam was convicted of violating 18 U.S.C. § 371 for conspiring to export goods from the United States to Iran without the required license. The 1760(e) order can be found here.

6 International Trade Enforcement Roundup |

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