Sanctions enforcement & export-controls — OFAC Iran/Venezuela/Belarus oil GL easing, SDN updates incl Ivanishvili/delistings, DOJ AI charges
Key Questions
What OFAC delistings were announced on April 6?
OFAC delisted Zadornov (Otkritie Rus banker), additional Russian vessels, and Delcy Rodríguez from Venezuela in a reversal. New delistings include Russia EO14024 entities, UAE/Turkey firms, cyber Finnish/SDNTK, and Honduras/Mexico narcos.
What is the new OFAC advisory on sham transactions?
OFAC issued a sanctions advisory warning against sham transactions for evasion, targeting financial institutions and businesses. It highlights risks in Iran/Venezuela/Belarus oil general licenses easing.
What smuggling cases involved AI chips?
BIS charged NVIDIA, AMD, SuperMicro with $2.5B smuggling of GPUs/servers to China, plus ASML DUV tools via MATCH. DOJ pursued chips/ITAR violations amid Iran IRISL boom via China for missile fuel.
What is Commerce's RFP for AI exports?
Commerce issued an RFP for secure AI exports to allies via G2G/interagency programs under the American AI Exports Program. This addresses export control modernization.
What bill did Wagner comment on?
Wagner stated support for the State/DoD/DOE export controls modernization bill, which fast-tracks controls on emerging tech like AI. It enhances interagency coordination.
What is the State Department notice on AECA violations?
State issued a 60-day Federal Register notice (to June 8) for proposed information collection on Arms Export Control Act violations disclosures. This improves compliance reporting.
How is Iran's merchant fleet faring amid sanctions?
Iran's IRISL is enjoying a boom despite war risks, with increased evasion via China for missile fuel and cargo. Higher risks lead to elevated cargo rates.
What leadership change at Commerce’s BIS?
George Forbes was named CIO at BIS amid rising focus on AI and tech controls. This supports enforcement against smuggling and evasion.
OFAC Apr6 delists: Zadornov (Otkritie Rus banker), addl Rus vessels/narcotics designees, Delcy redux; new delists Russia EO14024 UAE/Turkey firms/cyber Finnish/SDNTK Honduras/Mexico narcos; sham advisory; Iran/Ven GLs; BIS AI chips NVIDIA/AMD/SuperMicro $2.5B smuggling GPUs/servers to China + MATCH ASML DUV tools + Commerce RFP for secure AI exports to allies (G2G/interagency); DOJ chips/ITAR; Iran IRISL boom via China missile fuel; Chip Security Act signals trackers; Wagner stmt on State/DoD/DOE export controls modernization bill; State FR AECA violations disclosure notice (60-day to Jun8).