US sanctions 12 under INKSNA

The US has imposed new penalties on 12 individuals and companies for violations of its Iran, North Korea and Syria Nonproliferation Act (‘INKSNA’).

Six companies and two individuals in China, one company in Iraq, three firms in Russia, and one company in Turkey have been sanctioned. The parties include a leading Russian military design outfit and a Chinese provider of wireless communication and satellite navigation product testing solutions that lists its main markets as the US and Europe.

INKSNA allows for penalties on foreign entities and individuals ‘for the transfer to or acquisition from Iran since January 1, 1999; the transfer to or acquisition from Syria since January 1, 2005; or the transfer to or acquisition from North Korea since January 1, 2006, of goods, services, or technology controlled under multilateral control lists 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.’

The multilateral control lists referred to are the Missile Technology Control Regime, the Australia Group, the Chemical Weapons Convention, the Nuclear Suppliers Group, and the Wassenaar Arrangement.

According to the US Department of State, items falling into the category of ‘otherwise having the potential to make a material contribution to the development of weapons of mass destruction (WMD) or cruise or ballistic missile systems’ include the same kinds of items as those on multilateral lists but ‘falling below the control list parameters when it is determined that such items could materially contribute to WMD or cruise or ballistic missile systems, items on US 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’.

See: https://www.govinfo.gov/content/pkg/FR-2020-02-14/pdf/2020-02993.pdf