International Trade Law News

Published by Jacobson Burton Kelley PLLC

Yesterday the U.S. imposed sanctions on a number of entities and indviduals under the Iran, North Korea and Syria Nonproliferation Act (INKSNA).

The sanctioned entities are:

• Belarusian entities – Belarusian Optical Mechanical Association and BelTechExport;
• Chinese entities and individuals – Mr. Karl Lee, Dalian Sunny Industries, Dalian Zhongbang Chemical Industries Company, and Xian Junyun Electronic
• Iranian entities and individuals – Milad Jafari, Defense Industries Organization, Islamic Republic of Iran Shipping Lines (IRISL), Islamic Revolutionary Guard Corps Qods Force, SAD Import-Export Company, and Shahid Bakeri Industries Group
• North Korean entity – Tangun Trading
• Syrian entities – Industrial Establishment of Defense and Scientific Studies and Research Center
• Venezuelan entity – Venezuela Military Industries Company

Sanctions were imposed on these entities as provided in the INKSNA because there was credible information indicating that they had transferred to or acquired from Iran, North Korea, or Syria equipment and technology listed on multilateral export control lists (Australia Group, Chemical Weapons Convention, Missile Technology Control Regime, Nuclear Suppliers Group, Wassenaar Arrangement) or otherwise having the potential to make a material contribution to WMD or cruise or ballistic missile systems.

The sanctions apply to the specific entities above and will be in effect for two years. The sanctions do not apply to these entities’ respective countries or governments.

The sanctions that will be imposed on the entities and individuals listed above consist of the following:

• No department or agency of the U.S. Government may procure, or enter into any contract for the procurement of, any goods, services or technology from these entities;
• No department or agency of the U.S. Government may provide any assistance to these entities and they shall not be eligible to participate in any assistance program of the U.S. Government;
• U.S. Government sales of any item on the U.S. munitions list (USML) to any of these entities are prohibited, and sales of any defense articles, defense services or design and construction services controlled under the Arms Export Control Act are terminated; and
• New licenses will be denied and any existing licenses suspended, for transfer to these entities of items controlled under the Export Administration Act of 1979 or Export Administration Regulations.

Labels: North Korea, Sanctions; Iran, Sanctions; Syria