DOC BIS: Order Denying Export Privileges for criminal convictions pursuant to Section 1760(e) of the Export Control Reform Act (ECRA) (formerly known as 11h denials):
On October 20, Claudia Delgadillo was denied export privileges until October 9, 2029 (10 years from the date of her conviction). Delgadillo was convicted of violating 18 U.S.C. § 554(a) for the attempted export of various rifles and handguns to Mexico. The 1760(e) denial order can be found here. On October 28, Jose Martin Gallegos-Luevanos was denied export privileges until January 6, 2030 (10 years from the date of his conviction). Gallegos-Luevanos was convicted of violating 18 U.S.C. § 554(a) for attempting to export rifles and magazines to Mexico. The 1760(e) denial order can be found here. On September 30, Bryan Villanueva-Valles was denied export privileges until January 10, 2030 (10 years from the date of his conviction). Villanueva-Valles was convicted of violating 18 U.S.C. § 554(a) for attempting to export various rifles and handguns to Mexico. The 1760(e) denial order can be found here. On September 30, John James Peterson was denied export privileges until November 14, 2024 (5 years from the date of his conviction). Peterson was convicted of violating 18 U.S.C. § 371 for conspiring to export AR-15 assault rifle parts to Argentina without the required State Department licenses. The 1760(e) denial order can be found here. On September 30, Tito Calderon Olvera was denied export privileges until February 26, 2025 (5 years from the date of his conviction). Olvera was convicted of violating 18 U.S.C. § 554(a) for attempting to export handguns and magazines to Mexico. The 1760(e) denial order can be found here. On September 30, Mehdi Hashemi was denied export privileges until July 6, 2030 (10 years from the date of his conviction). Hashemi was convicted of violating the International Emergency Economic Powers Act for attempting to export computer numerical control machines to Iran via the United Arab Emirates. The 1760(e) denial order can be found here.
Enforcement Policy Updates
New CFIUS Guidelines
The guidelines. On October 20, CFIUS released new, non-binding Enforcement and Penalty Guidelines (Guidelines). The Guidelines follow last month’s Executive Order linking CFIUS reviews directly to the president’s national security prerogatives. In particular, the Guidelines detail the following: • Categories of conduct that constitute violations. • Sources of information CFIUS relies upon to determine whether a violation has occurred. • The process for developing and imposing penalties. • Aggravating and mitigating factors that CFIUS evaluates when deciding whether to impose a penalty. Notably. The issuance of the Guidelines pulls back the curtain a bit on how CFIUS should operate and the methods it uses to determine when and how to impose penalties. It is also indicative of an increasingly proactive and assertive CFIUS. While 2021 was historically busy for CFIUS, given the expansion of CFIUS jurisdiction over the past several years, it is likely that activities will increase even more in the future. Read more about the new guidelines in our Bass, Berry & Sims blog.
6 International Trade Enforcement Roundup |
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