Apple last week introduced a new ethics and compliance webpage, featuring a detailed outline of its trade compliance policies surrounding export controls and sanctions. A table of all Apple products provides their respective Export Control Classification Numbers and which destinations are blocked from receiving Apple products. The company said all its products qualify as mass market products and are subject to the Export Administration Regulations but are not controlled as dual-use goods by the Wassenaar Arrangement. Apple said some of its goods may be eligible for the Office of Foreign Assets Control’s Iranian General License No. D1 and Bureau of Industry and Security license exceptions related to Cuba. OFAC fined Apple about $465,000 in November 2019 after the company hosted, sold and helped transfer software applications and content belonging to a sanctioned company (see 1911250064).

The Office of Foreign Assets Control sanctioned Ahmad Hassan Mohammed al Asiri, Saudi Arabia’s former deputy head of the General Intelligence Presidency, and the country’s Rapid Intervention Force for their involvement in the 2018 murder of journalist Jamal Khashoggi. They were designated under the Global Magnitsky Human Rights Accountability Act for human rights violations, OFAC said Feb. 26.

In a case against an Iranian banker accused of violating U.S. sanctions on Iran, Judge Alison Nathan for the U.S. District Court for the Southern District of New York lambasted federal prosecutors over their mishandling of evidence and dereliction of responsibility. Stopping short of finding them guilty of knowingly withholding crucial information or intentionally misrepresenting facts to the court, Nathan in a Feb. 22 ruling called for a full investigation of the prosecutors' actions by the Department of Justice's Office of Professional Responsibility and said she hopes the government's reforms on evidence handling training will ensure that similar action is not repeated.

The Office of Foreign Assets Control imposed sanctions at a record pace during the Trump administration but saw a significant decline in enforcement actions and relied more heavily on voluntary disclosures as opposed to its own investigative resources, researchers said. Under President Donald Trump, OFAC also shifted its focus away from large financial institutions and instead targeted businesses in trade, manufacturing, travel and technology sectors, a trend that could promote more sanctions compliance across various industries.

The Office of Foreign Assets Control sanctioned two people involved in Myanmar’s military coup carried out earlier this month, OFAC said Feb. 22. The designations target Moe Myint Tun and Maung Maung Kyaw, who the State Department said are members of Myanmar's State Administrative Council. The move follows previous U.S. sanctions imposed on Myanmar this month, along with increased export restrictions (see 2102110020).

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The Office of Foreign Assets Control updated two sanctions entries for a Russian entity and a vessel involved in the construction of the Russian gas pipeline Nord Stream 2 (see 2101190018), according to a Feb. 22 notice. The agency added identifying information for the entries and other sanctions information. OFAC didn’t comment on the update.

An American animal pharmaceutical company may have violated U.S. sanctions after acquiring a company that illegally sold goods to Iran, Zoetis disclosed in a Feb. 16 Securities and Exchange Commission filing. Zoetis said it acquired Platinum Performance in August 2019 and soon discovered that Platinum had sold food, medicine or “devices” to people or entities with ties to Iran, adding that the sales were not approved by a Treasury Department general license. Zoetis submitted an initial voluntary disclosure to the Office of Foreign Assets Control in February 2020 while it conducted an internal investigation, and in December 2020 submitted a final disclosure to both OFAC and the Justice Department. The agencies have said they don't comment on ongoing investigations.

An Atlanta-based Bitcoin service provider was fined more than $500,000 for allowing people in sanctioned countries to use its services. BitPay committed more than 2,000 sanctions violations when it allowed people in Cuba, North Korea, Iran, Sudan, Syria and the Crimea region of Ukraine to use digital currency on the company’s platform to transact with U.S. parties, the Office of Foreign Assets Control said Feb. 18. The company allowed the transactions even though it had information that revealed the people were located in sanctioned regions, OFAC said, adding that “deficiencies” in the company’s compliance program led to the violations. The agency said BitPay allowed $129,000 worth of digital currency transactions that should have been blocked.

A Treasury Department spokesperson declined to say whether a decrease in sanctions settlements from 2019 to 2020 was due to issues caused by the COVID-19 pandemic, saying sanctions investigations are completed on a “variety of timelines.” The Treasury’s Office of Foreign Assets Control “takes its enforcement activities very seriously, and treats every matter with the care and due diligence that it deserves,” the spokesperson said in a Feb. 17 email. “These cases don’t always follow a set schedule, and we finalize cases when they’re ready and when we have all the facts and documentation necessary to draw the appropriate conclusion and finding.” The agency in 2019 settled 26 cases worth nearly $1.3 billion, compared with 16 cases totaling $23 million in 2020 (see 2102120061).