The Daily Bugle Weekly Highlights: Week 43 (19-23 Oct 2020)

Every Monday we post the highlights out of last week’s FCC Export/Import Daily Update (“The Daily Bugle”). Send out every business day to approximately 8,500 readers of changes to defense and high-tech trade laws and regulations, The Daily Bugle is a free daily newsletter from Full Circle Compliance, edited by James E. Bartlett III, Salvatore Di Misa, and Elina Tsapouri.

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Last week’s highlights of The Daily Bugle included in this edition are:

  1. Commerce/BIS: “Relief for Exporters with Six-Month Extension on Licenses”; Monday, 19 Oct 2020; Item #4
  2. EU Council Imposing Certain Specific Restrictive Measures in Violation of the Arms Embargo with Regard to The Democratic Republic of The Congo; Monday, 19 Oct 2020; Item #6
  3. EU Council: “EU Renews Its Sanctions Regime Against ISIL/Da’esh and Al-Qaida Until 31 Oct 2021”; Tuesday, 20 Oct 2020; Item #7
  4. EU External Action: “Non-Proliferation Treaty: Remarks by the High Representative/Vice-President Josep Borrell”; Wednesday, 21 Oct 2020; Item #6
  5. Treasury/OFAC Sanctions Iranian Ambassador to Iraq; Friday, 23 Oct 2020; Item #5



Commerce/BIS: “Relief for Exporters with Six-Month Extension on Licenses”

(Source: Commerce/BIS, 16 Oct 2020)


  Recognizing the importance of exports during this time of economic transition and recovery, the Bureau of Industry and Security (BIS) in the U.S. Department of Commerce is highlighting the opportunity for exporters to request six-month validity period extensions for licenses due to expire on or before December 31, 2020. 

  “With the majority of the world’s consumers located outside of the United States, exports are a vital source of growth and revenue for American companies,” said Acting Under Secretary for Industry and Security, Cordell Hull. “President Trump and the Department of Commerce are committed to cutting red tape and making it easier for exporters to drive our Nation’s economic recovery in the wake of the pandemic.” BIS will streamline the extension of the validity process by creating a central electronic mailbox for submission of requests at The original license will be reviewed and, in most cases, the validity extended via the electronic system. 

  Depending on the number of requests received, it is estimated that the majority of extension validity requests will be processed and approved within two to three business days. “The streamlined process will help ensure that exporters with licenses due to expire on or before the end of 2020, who may not have been able to ship orders due to resource constraints during the pandemic, have the opportunity to benefit fully from the authorizations granted on their licenses,” said Hull. “The Trump Administration is focused on easing the way for American businesses to export during this crucial time.”



EU Council Imposing Certain Specific Restrictive Measures in Violation of the Arms Embargo with Regard to The Democratic Republic Of The Congo

(Source: Official Journal of the European Union, 19 Oct 2020)


The Council of the European Union,

Having regard to the Treaty on the Functioning of the European Union,

Having regard to Council Regulation (EC) No 1183/2005 of 18 July 2005 imposing certain specific restrictive measures directed against persons acting in violation of the arms embargo with regard to the Democratic Republic of the Congo, and in particular Article 9(5) thereof,

Having regard to the proposal from the High Representative of the Union for Foreign Affairs and Security Policy,


(1) On 18 July 2005, the Council adopted Regulation (EC) No 1183/2005.

(2) On 19 August 2020, the United Nations Security Council Committee established pursuant to United Nations Security Council Resolution 1533 (2004) amended the listings for two persons and three entities subject to restrictive measures.

(3) Annex I to Regulation (EC) No 1183/2005 should therefore be amended accordingly,


Article 1

Annex I to Regulation (EC) No 1183/2005 is hereby amended as set out in the Annex to this Regulation.

Article 2

This Regulation shall enter into force on the day following that of its publication in the Official Journal of the European Union.

This Regulation shall be binding in its entirety and directly applicable in all Member States.

Done at Brussels, 16 October 2020.



EU Council: “EU Renews Its Sanctions Regime Against ISIL/Da’esh and Al-Qaida Until 31 Oct 2021”

(Source: Council of the European Union, 19 Oct 2020)


  The Council today renewed the EU sanctions regime against ISIL/Da’esh and Al-Qaida and the related list of people subject to restrictive measures for another year until 31 October 2021. The decision was taken in light of the ongoing terrorist threat.

  EU sanctions consist of a travel ban to the EU and an asset freeze for individuals, and an asset freeze for groups and entities. In addition, EU persons and entities are forbidden from making funds and economic resources available to those listed.

  Five individuals are currently subject to restrictive measures.

The EU has been able to autonomously adopt restrictive measures against ISIL (Da’esh) and Al-Qaeda, and persons, groups, undertakings and entities associated with them, since September 2016. The EU regime is independent from, but complementary to, the regime allowing for sanctions to be adopted at the UN level.

  The relevant legal act will be published in the Official Journal of the European Union on 20 October 2020.



EU External Action: “Non-Proliferation Treaty: Remarks by the High Representative/Vice-President Josep Borrell”

(Source: European Union External Action, 20 Oct 2020) [Excerpts]


  We are all concerned about the deteriorating security environment as well as the continued pressure on the nuclear non-proliferation architecture, illustrated by the demise of the Intermediate-Range Nuclear Forces in Europe Treaty. We regretted it a lot when it happened and we continue regretting it now.

  It is essential that all States Parties comply with their Non-Proliferation Treaty obligations and fully implement all commitments under the Treaty.

  Upholding and preserving the Non-Proliferation Treaty must remain a key priority for the European Union’s foreign policy. The European Union strongly supports all three pillars of the Treaty – non-proliferation, nuclear disarmament and peaceful uses of nuclear energy – and will continue to promote comprehensive, balanced and full implementation of the 2010 Review Conference Action Plan.

  Through intensive diplomatic engagement backed up by the [Common Foreign and Security Policy] (CFSP) funded Council Decisions we are promoting the ratification of the Comprehensive Test Ban Treaty and the preparations of negotiations for a Fissile Material Cut-off Treaty. We are also proud to support regional conferences in preparation for the Non-Proliferation Treaty Review Conference. 

  We are going to redouble our efforts to uphold international norms, to restore dialogue and trust, and to promote transparency and confidence-building measures.

  Together with Member States, we are preparing a strong and forward-looking common European Union position for the Non-Proliferation Treaty Review Conference. And I would like to stress some of the key elements of our position in the context of your Report. …



Treasury/OFAC Sanctions Iranian Ambassador to Iraq

(Source: Treasury/OFAC, 22 Oct 2020)


  Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is designating Iraj Masjedi, a general in Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) and Iran’s Ambassador to Iraq, for acting for or on behalf of the IRGC-QF. A close adviser to former IRGC-QF Commander Qassem Soleimani, Masjedi played a formative role in the IRGC-QF’s Iraq policy. In his decades of service with the group, Masjedi has overseen a program of training and support to Iraqi militia groups, and he has directed or supported groups that are responsible for attacks that have killed and wounded U.S. and coalition forces in Iraq. In his current capacity, Masjedi has exploited his position as the Iranian regime’s ambassador in Iraq to obfuscate financial transfers conducted for the benefit of the IRGC-QF.

  “The Iranian regime threatens Iraq’s security and sovereignty by appointing IRGC-QF officials as ambassadors in the region to carry out their destabilizing foreign agenda,” said Secretary Steven T. Mnuchin. “The United States will continue to employ the tools and authorities at its disposal to target the Iranian regime and IRGC-QF officials that attempt to meddle in the affairs of sovereign nations, including any attempts to influence U.S. elections.”

  Masjedi is being designated pursuant to the counterterrorism authority Executive Order (E.O.) 13224, as amended, for acting or purporting to act for or on behalf of, directly or indirectly, the IRGC-QF. The IRGC-QF was designated pursuant to E.O. 13224 in 2007 for support to numerous terrorist groups. The IRGC, including its external arm, the IRGC-QF, was designated as a Foreign Terrorist Organization on April 8, 2019.



  Iran’s ambassador to Iraq since 2017, Masjedi has publicly admitted the IRGC-QF’s role in special operations and the training of militia groups in Iraq, Syria, and beyond. He claims credit for organizing and supporting regional militias to advance Iran’s interests throughout the Middle East an enterprise that has spawned untold destruction and corruption, robbing Iraq of a stable, prosperous future.

  Masjedi has facilitated financial transfers for the benefit of the IRGC-QF in coordination with IRGC-QF financial facilitator Hushang Allahdad, acting at the direction of former IRGC-QF Commander Soleimani and his successor, Esma’il Ghani. Soleimani was designated pursuant to multiple authorities, including E.O. 13224, in 2011, while Allahdad and Ghani were designated pursuant to E.O. 13224 in 2010 and 2012, respectively. Since 2018, Masjedi has helped the IRGC-QF obtain foreign currency in Iraq, in return for equivalent sums that the IRGC-QF in Iran has transferred to relevant entities. Most recently, Masjedi has provided direct assistance in obtaining tens of billions of dinars on behalf of the IRGC-QF in Iraq.

  In the decades prior to his ambassadorial appointment, Masjedi was a senior figure overseeing IRGC-QF activities in Iraq, which included attacks targeting U.S. and coalition personnel, as well as kidnappings and the assassination of Iraqi provincial officials who sought to curb Iranian influence in Iraq. The IRGC-QF provided training for Iraqi recruits, often inside Iran. The Iraqi recruits hailed from groups loyal to, and supported by, the IRGC-QF, which help maintain Iranian influence in Iraqi politics and security. The IRGC-QF also manufactured and distributed weapons, including explosively formed penetrators, that killed and wounded hundreds during Operation Iraqi Freedom.

Masjedi is being designated pursuant to E.O. 13224, as amended, for acting or purporting to act for or on behalf of, directly or indirectly, the IRGC-QF.



  All property and interests in property of the individual designated today, subject to U.S. jurisdiction, are blocked, and U.S persons are generally prohibited from engaging in transactions with him or the blocked property. In addition, foreign financial institutions that knowingly facilitate significant transactions for, or persons that provide material or certain other support to, the individual designated today risk exposure to sanctions that could sever their access to the U.S. financial system or block their property and interests in property under U.S. jurisdiction.


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