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A New Hampshire charity delivering humanitarian aid to Syria was sentenced in federal court for export offenses.   NuDay was sentenced December 28 by U.S. District Court Judge Joseph N. Laplante to five years of probation, the maximum penalty for an organizational defendant.  NuDay was also ordered to pay a $25,000 fine.  On September 8, 2023, NuDay pleaded guilty to three counts of Failure to File Export Information.

Treasury’s Office of Foreign Assets Control (OFAC) designated one individual and three entities responsible for facilitating the flow of Iranian financial assistance to Houthi forces in Yemen. Among those designated today is the head of the Currency Exchangers Association in Sana’a, and three exchange houses in Yemen and Türkiye.

The Commerce Department's October 27 "pause" in the issuance of new export licenses involving firearms under its jurisdiction is expected to end this month, and industry and its friends in Congress are girding for battle. The Protect American Gun Exporter Act introduced by Sen. Mike Lee (R-UT) seeks to forbid the Secretary from similar actions in the future and bar "unilateral' policy changes, while a leaked Commerce document proposes quite a few. In a  draft Federal Register Notice obtained by the website "The Reload" marked "predecisional"  Commerce proposes the addition of two new ECCNs, enhanced documentation requirements and other changes to improve traceability and control of the civilian arms trade.

China announced it will impose sanctions on a United States company and two individuals in reaction to similar measures taken by the U.S. against Chinese officials and entities. The December 26 sanctions target Kharon, a U.S. intelligence data firm, its director of investigations Edmund Xu, and former researcher Nicole Morgret. These sanctions are a response to allegations and measures concerning the situation in the Xinjiang Uygur autonomous region.

The planned acquisition by Nippon Steel of what used to be America's preeminent steelmaker has stirred up a hornet's nest of jingoism and grandstanding in Washington and the Rust Belt, promising for a contentious review by the Committee on Foreign Investment in the US (CFIUS). "President Biden welcomes foreign investment that creates new US manufacturing jobs,"  National Economic Council Director Lael Brainard said.  “However, he also believes the purchase of this iconic American-owned company by a foreign entity – even one from a close ally – appears to deserve serious scrutiny in terms of its potential impact on national security and supply chain reliability,” 

The United States and other countries participating in the Price Cap Coalition announced new rules aimed at making it harder to Russia to circumvent the price cap imposed on Russian oil in response to its invasion of Ukraine. “These changes will further complicate efforts by Russian exporters to circumvent the price cap while deceiving Coalition service providers, and further raise costs for any Russian exporters that need premier services but are unwilling to sell oil under the cap,” according to the coalition's announcement December 21.. The changes include requiring that relevant Coalition service providers receive attestations from their counterparties each time they lift or load Russian oil. The coalition also is introducing changes that will require supply chain participants with access to itemized ancillary costs (e.g., insurance and freight) to share these upon request with entities further down the supply chain.

The United States announced new listings of four Nicaraguan, four Guatemalan, three Honduran, and three Salvadoran individuals under the Section 353 Corrupt and Undemocratic Actors report.  …

The Administration imposed sanctions on 10 entities and four individuals in order to disrupt a procurement network across the Middle East and East Asia supporting Iran’s unmanned aerial vehicle production. Being targeted by the Treasury Department’s Office of Foreign Assets Control December 19 are entities and individuals based in Iran, Malaysia, Hong Kong and Indonesia.

The Treasury Department announced it has published public comments received on the draft Organization for Economic Cooperation and Development/G20 Inclusive Framework Multilateral Convention to Implement Amount A of Pillar One and accompanying documents. Pillar One aims to tax corporate profits to countries based on customer location, not the entity's legal domicile.

FinCEN has determined entities which will be permitted access to the new centralized register of beneficial ownership being established under the Corporate Transparency Act.    FinCEN will permit certain Federal, State, local, and Tribal officials, as well as foreign officials acting through a Federal agency, to obtain BOI, as well as financial institutions with customer due diligence requirements under applicable law to have access to BOI from the new centralized database.

The European Council adopted Monday a twelfth package of economic and individual restrictive measures in view of the continued Russian war of aggression against Ukraine.

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 The United States announced the resolution of another USMCA Rapid Response Labor Mechanism (RRM) dispute at a  Caterpillar, Inc. subsidiary in Nuevo Laredo, that produces remanufactured auto parts. The plant's workers remain on strike. After the United States requested Mexico’s review of the matter, Mexico and the company took several actions to address the denials of rights the United States found, including actions to reinstate dismissed workers and correct other employer interference in union activities.

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced a $466,200 settlement with Privilege Underwriters Reciprocal Exchange (PURE). PURE agreed to settle its potential civil liability for 39 apparent violations of OFAC's Ukraine-/Russia-Related sanctions. Based in White Plains, New York, PURE primarily offers insurance policies and coverages for luxury homes, automobiles, art collections, jewelry, and watercraft

Friday, the President signed a new Russia-related Executive Order advising financial institutions and payments processors that "Foreign financial institutions that conduct or facilitate significant transactions or provide any service involving Russia’s military-industrial base run the risk of being sanctioned by OFAC." Under these new authorities, OFAC can impose full blocking sanctions on, or prohibit or restrict the maintenance of correspondent accounts in the United States for, foreign financial institutions.

Goods imported into the UK from countries with a lower or no carbon price will have to pay a levy by 2027, ensuring products from overseas face a comparable carbon price to those produced in the UK.  The carbon border adjustment mechanism (CBAM) will ensure highly traded, carbon intensive products from overseas in the iron, steel, aluminium, fertiliser, hydrogen, ceramics, glass and cement sectors face a comparable carbon price to those produced here.

In coordination with Treasury and Justice, the State Departemnt  named three Chinese firms for the proliferation ofthe proliferation of weapons of mass destruction and the means of delivering them. The three firms, based in Hong Kong, Beijing and Changzhou, respectively were cited by the Under Secretary of State for Arms Control and International Security added the entities to the the list of Specially Designated Nationals and Blocked Persons.

Operation Car Wash, the wide ranging graft case involving Petrobras officials and the commodity trading community snared another trophy culprit. Stamford, Connecticut based Freepoint Commodities agreed to pay the DOJ $98 million to resolve an investigation into bribery of Brazilian government officials. The firm has also agreed to pay more than $7.6 million to the Commodity Futures Trading Commission in a related matter.

The United States is once again asking the Mexican government to review worker rights violations at a automotive plant under the US-Mexico-Canada Agreement’s rapid response labor mechanism. The latest request is for Mexico to look at whether workers at the Fujikura Automotive Mexico facility in Piedras Negras in the state of Coahuila are being denied the right to freedom of association and collective bargaining, including through the company blacklisting or otherwise retaliating against workers because of union activity at their prior employer, Manufacturas VU. …

In a wide ranging conversation at Georgetown University, Under Secretary of Commerce for Industry and Security Alan Estevez shared his perspective on the evolution of export controls and the road ahead. "I believe now that we are at sort of a foundational inflection point as to the role and purpose of export controls," Estevez said. " Commerce is in the middle of national security in a number of spheres these days.

"We do it from two perspectives. We do it from offense and we do it from defense. Offense is things like Chips Act. So how are we going to build chip production in the United States, where we have assured supply? Semiconductors are the foundation of a lot of what goes on in our economy. "The core of the defense structure is our export controls. Protecting the technology that our adversaries could use against us, should it ever come to any kind of kinetic action...

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