You are reading the October 2023 Update of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox.
Overview
- October saw two major enforcement actions involving Russia. First, three individuals were indicted for facilitating the export of controlled U.S.-origin electronics to Russia. Second, the president of a U.S. steel trading company pleaded guilty to sanctions violations for transacting with a designated Russian oligarch.
- There were also several notable U.S. sanctions matters in October. The U.S. Treasury Department Office of Foreign Assets Control (OFAC) issued two tranches of sanctions targeting Hamas financial networks. In addition, U.S. sanctions on Venezuela were eased through the issuance of four General Licenses (GLs). And a U.S. citizen pleaded guilty to violating the International Emergency Economic Powers Act (IEEPA) for exceeding the scope of an OFAC license related to Iran.
- October also saw a number of enforcement policy updates. The Departments of Justice, Commerce, State and Treasury issued an advisory alert detailing the threats posed by Iran's procurement efforts for its ballistic missile programs. In addition, after issuing rules in 2022 to control various types of advanced semiconductors, the Commerce Department's Bureau of Industry and Security (BIS) issued new rules strengthening and clarifying those requirements.
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