Ancient artifact from Iran seized by US Customs.

Seized Iranian vase, source: CBP.gov

U.S. Customs and Border Protection (CBP) Officers in Kentucky seized a shipment containing an antique amber glass bottle believed to be an antique from the 9th to 10th century. CBP officers forwarded the antique to a subject matter export who examined the bottle and determined the bottle was from Iran between the 11th and early 13th centuries.

The shipment from the UK bound for an address in Colorado was unfortunately seized for Office of Foreign Asset Control (OFAC) violations. As you are aware, current OFAC rules prohibit the importation of goods or services from Iran. OFAC is a department under the U.S. Treasury and enforces economic and trade sanctions against certain countries and individuals who are believed to be involved with terrorism, narcotics, human trafficking or other illegal and disreputable activities.

Besides OFAC issues, CBP also helps protect cultural property and keeps antiques with their rightful owners. The seized Iranian vase will be returned to Iran.

In addition to merchandise from Iran, OFAC regulations prohibit importation of goods and services from Cuba, Burma (Myanmar), and most of Sudan. Certain exceptions can be made but do require an OFAC license for those importations.

If you have any questions about OFAC enforcement or compliance, contact David Hsu by phone/text anytime at 832-896-6288 or by email at: attorney.dave@yahoo.com.

OFAC reaches settlement with Kollmorgen over Iran sanctions violations.

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Photo by Burkay Canatar on Pexels.com

According to a press release from the U.S. Department of the Treasury:

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) today announced a $13,381 settlement with Kollmorgen Corporation (“Kollmorgen”) of Radford, Virginia. Kollmorgen has agreed to settle potential civil liability on behalf of its Turkish affiliate Elsim Elektroteknik Sistemler Sanayi ve Ticaret Anonim Sirketi (“Elsim”) for six apparent violations of Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR). The apparent violations involved Elsim dispatching employees to Iran to service machines and providing other services to Iran in violation of ITSR § 560.215. OFAC determined that Kollmorgen voluntarily self-disclosed the apparent violations on behalf of Elsim and that the apparent violations constitute a non-egregious case.

If you have any questions about the Iran sanctions, want to update your OFAC compliance program or have concerns that your company or any affiliate is violating OFAC sanctions on Iran, call David Hsu at 832-896-6288 or by email at attorney.dave@yahoo.com.

Sudan joins the UN’s Convention on the Recognition and Enforcement of Foreign Arbitral Awards.

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Credit: Wikipedia 

In October 2017, the US revoked certain sanctions against Sudan and the Sudanese government. These sanctions include those put in place by then-President Clinton (Executive Order 13067) and then-President Bush (Eexecutive Order 13412). However, OFAC sanctions related to the conflict in Darfur: EO 13400, EO 13067.

Following the removal of sanctions, the Sudanese government has made efforts to increase foreign investment – with the Sudanese state minister touring Germany, Bahrain and other countries in December 2017.

In a move to further increase foreign investment to Sudan, on Tuesday, April 3rd, Sudan joined the network of countries that agree to enforce and recognize other nation’s arbitral awards. By joining this network, the Sudanese government hopes to increase confidence of foreign investors – especially in Sudan’s oil and gas sector.

Nations that sign the UN Convention on the Recognition and Enforcement of Foreign Arbitral Awardshe Signatories to the New York Convention agree to recognize arbitration agreements and enforce awards issued in other countries party to the rules. This agreement is viewed as the basis for international arbitration and allows a way for companies to settle commercial disputes.

The removal of 20 years of trade and financial sanctions will allow U.S. citizens and companies to now do business in Sudan, including deals with their government. However, U.S. citizens and companies are still probibited from conducting business with parties on the OFAC list.

If you or your company is planning to invest in Sudan, contact our offices, we can verify compliance with the most recent OFAC list and assist your company in taking all efforts to maintain export compliance – David Hsu, 832-896-6288 or by email at attorney.dave@yahoo.com.