February - 2019

OFAC’s OCE issues new document about data delivery standards

On 26 February 2019 the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) Office of Compliance and Enforcement (“OCE”) announced a document describing its new data delivery standards. This document supersedes and replaces OFAC Enforcement’s 2013 Data Delivery Standards. The OCE data delivery document gives the preferred formatting and technical standards for electronic documents submitted to the OCE, such as subpoena responses and self-disclosures.

US DEA launches a new tool in its online reporting system ARCOS

On 26 February 2019 the United States’ Drug Enforcement Administration (DEA) announced that an upgraded feature of its Automated Reports and Consolidated Orders System (ARCOS) is now active. This new feature allows DEA-registered manufacturers and distributors access to the number of distributors and the amount each distributor sold to a prospective customer. The “Substance Use–Disorder Prevention that Promotes Opioid Recovery and Treatment (SUPPORT) for Patients and Communit

OFSI penalizes Raphaels Bank

On 21 February 2019 the United Kingdom’s Office of Financial Sanctions Implementation (OFSI) issued its first monetary penalty against Raphaels Bank for £5,000.00. This penalty was given in accordance with s146 of the Policing and Crime Act 2017 for the breach of regulation 3 of the Egypt (Asset-Freezing) Regulations 2011 (S.I. 2011/887). According to the report by OFSI, the breach occurred when a £200.00 transaction was performed by Raphaels Bank for a person designated unde

OFAC settles with ZAG IP, LLC

On 21 February 2019 the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a settlement with U.S. company ZAG IP, LLC (formerly known as ZAG International, LLC) (“ZAG”). ZAG’s $506,250 settlement with OFAC is for five apparent violations of § 560.206 of the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR). Apparently, between the approximate dates of 11 July 2014 and 15 January 2015, ZAG purchased cement clinker from a

Notice to our customers regarding Brexit

(This notice can be found below in German.) One of the biggest challenges we face in the immediate future is Brexit. We want to assure you that we are committed to providing the smoothest transitional period possible by monitoring all legislative developments regarding Brexit, both those that come from the UK as well as those originating in the EU. Compliance Fortunately, one legislative topic, compliance, has already been determined. The new law "Sanctions and Anti-Money Lau

UK publishes 3 updated OGELs that now include a software control list entry

Today, 18 February 2019, the United Kingdom’s Department for International Trade: Export Control Joint Unit (ECJU) has published three updated and amended open general export licences (OGELs). These licences now include an entry that specifically refers to software that is designed both for military use and for other communications applications. These revised licences come into force on 18 February 2019.

OFAC assesses penalty against AppliChem GmbH

On 14 February 2019 the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a civil monetary penalty of $5,512,564 against AppliChem GmbH (“AppliChem”) of Darmstadt, Germany. Between May 2012 and February 2016 AppliChem violated the Cuban Assets Control Regulations, 31 C.F.R. part 515 over 300 times by fulfilling Cuban orders of chemical reagents. AppliChem is owned by Illinois Tool Works, Inc. (“ITW”), a company based in Glenview, Illinois. Al

European Parliament approves EU and Singapore trade and investment agreements

On 13 February 2019 the European Parliament approved trade (EU-Singapore Free Trade Agreement, “EUSFTA”) and investment (EU-Singapore Investment Protection Agreement, “EUSIPA”) agreements between the European Union and Singapore. The EUSFTA will be the first free trade agreement between the EU and an ASEAN (Association of Southeast Asian Nations) country and will come into force after it is ratified by both parties. Under this agreement, Singapore will remove tariffs from all

European Commission adopts new list of countries with AML/CTF deficiencies

On 13 February 2019 the European Commission adopted a new list of 23 countries with deficiencies in their anti-money laundering and counter-terrorist financing (AML/CTF) regimes. This newly published list replaces the list that has been in place since July 2018. This new list is a product of the Commission’s own methodology, which it has developed to assess AML/CTF deficiencies specifically within the European Union's financial system. This methodology not only relies on info

UK and Switzerland sign trade agreement

On 11 February 2019 the United Kingdom’s International Trade Secretary, Liam Fox, and the Swiss Federal Councillor, Guy Parmelin, signed a trade continuity agreement. This new trade agreement will come into force as soon as the Swiss/EU agreements no longer apply between Switzerland and the UK. Therefore, if the UK leaves the EU with a deal, the Swiss/EU agreements will continue to apply to the UK during the transition period. However, in the case that the UK leaves the EU wi

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