Jeffrey I. Snyder

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The Countering America’s Adversaries Through Sanctions Act (CAATSA) was signed into law by President Trump on August 2, 2017. This put in motion several deadlines, three of which are due next Monday, January 29, 2018. Based on past experience, the Trump administration may not meet these deadlines. Nonetheless, it is clear that the impact of these sanctions will be felt differently by different sectors of the U.S. economy. This is an opportunity for industries to…
  On January 11, BIS announced a Settlement Agreement with MHz Electronics, Inc. of Phoenix, AZ, to settle its potential civil liability for two alleged violations of the Export Administration Regulations (EAR). Charges Details Summary Enforcement Action § 764.2(a) Engaging in Prohibited Conduct On two occasions in 2013, the company exported pressure transducers subject to the EAR under Export Control Classification Number (ECCN) 2B230 without a license to China and Taiwan Civil Monetary Penalty of…
Office of Foreign Assets Control (OFAC) On December 6, OFAC announced that DENTSPLY SIRONA Inc. (DSI), a U.S. company incorporated in Delaware, the successor in interest to DENTSPLY International Inc. (DII), agreed to pay $1.2 million to settle its potential civil liability for 37 apparent violations of the Iranian Transactions and Sanctions Regulations. Between 2009 and 2012, DII subsidiaries exported 37 shipments of dental equipment and supplies from the U.S. to third countries, with knowledge…
On December 20, 2017, the Court of Justice of the European Union (CJEU) decided that a company may not use transaction value for customs valuation purposes when a transfer price consisted of both an amount initially invoiced and declared, and a flat-rate adjustment made after the end of the accounting period. The Community Customs Code (CCC) and its related jurisprudence provides that customs value must be determined primarily according to the transaction value method, with…
Blockchains and distributed ledger technology (‘DLT’) are becoming increasingly prevalent in industry. A recent Juniper Research survey found that 56% of companies with more than 20,000 employees were either considering deploying, or were in the process of deploying, blockchain solutions. At its core, blockchain technology is essentially an engine for processing exchanges of information. It is not a static record. A blockchain is a type of distributed database that tracks transactions in assets and exchanges…
On January 8, the Treasury Department published its quarterly ‘List of Countries Requiring Cooperation with International Boycott’ in the Federal Register. On the basis of the best information currently available to the Department of the Treasury, the following countries require or may require participation in, or cooperation with, an international boycott (within the meaning of section 999(b)(3) of the Internal Revenue Code of 1986: Iraq, Kuwait, Lebanon, Libya, Qatar, Saudi Arabia, Syria, United Arab Emirates,…
Despite increased pressure from the U.S. and the UN Security Council, human rights groups estimate about 16 countries still host North Korean laborers. A recent estimate by the Korea Institute for National Unification in Seoul puts the number of North Korean workers overseas at around 147,000. Most work in China and Russia, but reports continue to surface of North Korean workers even in EU countries. In Poland for instance, a recent New York Times
CBP has revised its informed compliance publication regarding Reasonable Care to include a section regarding forced labor. Additionally, seafood and apparel industries appear to be recent targets of CBP Requests for Information CF28’s regarding forced labor in their supply chain. Although admittedly, the CF28s may also be as a consequence of the passage of the Countering America’s Adversaries through Sanctions Act (CAASA). P.L. 115-44. CAASA created a presumption that “significant goods, wares, articles, and merchandise mined, produced,…
On November 16, Lithuania became the third EU Member State to pass a law against human rights abuses in Russia in the name of Sergei Magnitsky, a lawyer who died in Russian jail in 2009 after exposing fraud by Russian officials. Such a law was initially enacted in the United States in 2012 as the Sergei Magnitsky Rule of Law Accountability Act, imposing travel and banking restrictions on Russian officials implicated in human rights abuses. Since then,…
Office of Foreign Assets Control (OFAC) On November 17, American Express Company (AMEX) agreed to pay $204,277 to settle its potential civil liability for 1,818 alleged violations of the Cuban Assets Control Regulations (CACR). The violations occurred between 2009 and 2014, at which time a wholly-owned subsidiary of AMEX, Alpha Card Group, owned 50 percent of BCC Corporate SA (BCCC), a Belgium-based credit card issuer and corporate service company. Alpha Card and BCCC failed…