Iran, North Korea, and Syria Nonproliferation Act Sanctions
MEDIA NOTE
OFFICE OF THE SPOKESPERSON
WASHINGTON, DC
MARCH 24, 2017
On March 21, the United States imposed sanctions on 30 foreign entities and individuals in 10 countries pursuant to the Iran, North Korea, and Syria Nonproliferation Act (INKSNA). These sanctions apply to the specific individuals and entities which will be listed in the federal register and will be in effect for two years. The sanctions do not apply to these individuals and entities’ respective countries or governments. These sanctions exemplify the U.S. government’s continued commitment to Nonproliferation and the promotion of global stability and security.
As part of the March 21 sanctions, a group of eleven entities and individuals were sanctioned for transfers of sensitive items to Iran’s ballistic missile program. Iran’s proliferation of missile technology significantly contributes to regional tensions. As an example, we have seen indications Iran is providing missile support to the Houthis in Yemen. This destabilizing activity only serves to escalate regional conflicts further and poses a significant threat to regional security. We will continue to take steps to address Iran’s missile development and production and sanction entities and individuals involved in supporting these programs under U.S. law. The imposition of sanctions against these eleven foreign entities is a continuation of our commitment to hold Iran accountable for its actions.
The eleven entities sanctioned under the INKSNA on March 21 specifically for transfers to Iran’s missile program are:
Beijing Zhong Ke Electric Co. Ltd. (ZKEC) (China)
Dalian Zenghua Maoyi Youxian Gongsi (China)
Jack Qin (Chinese individual)
Jack Wang (Chinese individual)
Karl Lee [aka Li Fangwei] (Chinese individual)
Ningbo New Century Import and Export Company Limited (China)
Shenzhen Yataida High-Tech Company Ltd (China)
Sinotech (Dalian) Carbon and Graphite Corporation (SCGC) (China)
Sky Rise Technology [aka Reekay Technology Limited] (China)
Saeng Pil Trading Corporation (SPTC) (North Korea)
Mabrooka Trading (United Arab Emirates).
An additional 19 foreign entities and individuals were sanctioned under INKSNA on March 21 for other violations. These entities and individuals were sanctioned as a result of a determination that there was credible information indicating they had transferred to, or acquired from, Iran, North Korea, or Syria goods, services, or technology listed on multilateral export control lists; or on U.S. national control lists, or other items that could make a material contribution to the development of weapons of mass destruction or missile proliferation. These determinations were the result of a periodic review of sanctionable activity as required by the INKSNA. These determinations underscore that the United States continues to regularly impose sanctions under existing authorities, as warranted, against entities and individuals that engage in proliferation activity with Iran, North Korea, and Syria.
The following restrictions will go into effect on the sanctioned individuals and entities effective March 21.
*No department or agency of the U.S. Government may procure or contract for any goods, services, or technology from the designated entities, except to the extent the Secretary of State otherwise may determine;
*The designated entities are ineligible for any assistance program of the U.S. Government, except to the extent the Secretary of State otherwise may determine;
*S. Government sales of any item on the U.S. Munitions List to 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 transfers of export- controlled items.
*For more information contact [email protected]
1) This notice announces "secondary sanctions" against a handful of Chinese and Russian persons pursuant to the INKSNA, a "secondary sanctions" statute that is often overlooked because it is seldom invoked and does not include any OFAC-administered sanctions provisions, e.g. blocking. Here, sanctions were all imposed on persons that had not previously been subject to sanctions. None of those on whom sanctions were imposed were, concurrent with this action by the Department of State, made subject to any OFAC-administered sanctions authority.
The announcement is worth taking note of in light of the fact that, at the time it was made, the activities deemed sanctionable may have been within the scope of several Iran-specific, OFAC-administered secondary sanctions authorities. According to the announcement, most of the sanctioned persons were sanctioned "for the transfer to or acquisition from Iran...of goods, services, or technology controlled under multilateral control lists (Missile Technology Control Regime, Australia Group, Chemical Weapons Convention, Nuclear Suppliers Group, Wassenaar Arrangement) or otherwise having the potential to make a material contribution to the development of weapons of mass destruction (WMD) or cruise or ballistic missile systems [of Iran]. The latter category includes items of the same kind as those on multilateral lists but falling below the control list parameters when it is determined that such items have the potential of making a material contribution to WMD or cruise or ballistic missile systems, items on U.S. national control lists for WMD/missile reasons that are not on multilateral lists, and other items with the potential of making such a material contribution when added through case-by-case decisions."
Not enough detail is provided to determine whether the activities were secondary sanctionable pursuant to one or more authorities that would have required blocking, but compare New Sanctions Under the Iran, North Korea, and Syria Nonproliferation Act (INKSNA) (NOVEMBER 27, 2020) and Feb. 14, 2020 Imposition of Nonproliferation Measures Against Foreign Persons. INKSNA appears to be used as a means of sanctioning entities whose conduct may be within the theoretical scope of blocking authorities, but is not considered to merit full blocking.
2) Note that this notice is illustrative, and that we do not include all INKSNA announcements in the Research System because the sanctions are neither imposed nor administered by OFAC. See State Department Non-Proliferation "Master Sanctions Chart" (INKSNA, IIANPA, CBW Act, Others), for a comprehensive list of sanctions imposed pursuant to INKSNA and similar authorities.