Publication of “A Framework for OFAC Compliance Commitments”

Yesterday, the U.S. Treasury’s Office of Foreign Asset Controls (OFAC) published A Framework for OFAC Compliance Commitments. The purpose of the framework is to provide organizations subject to U.S. jurisdiction, as well as foreign entities that conduct business in or with the United States or U.S. persons, or that use U.S.-origin goods or services, with guidelines on the essential components of a sanctions compliance program. The document also outlines how OFAC may incorporate these components into its evaluation of apparent violations and resolutions of investigations resulting in settlements.  Finally, the document includes an appendix that offers a brief analysis of some of the root causes of violations of U.S. economic and trade sanctions programs.

Joe O’Mara

We note the passing of friend and colleague Joe O’Mara on Saturday, April 27. Joe’s storied career included postings with USDA FAS in Brazil, Argentina and Switzerland and concluded as Counsel for International Affairs to the Secretary of Agriculture, concurrently serving as the Special Trade Negotiator for Agriculture for both the Uruguay Round of the GATT and the NAFTA. Joe worked with NAEGA in many ways including on the Export Credits Working Group.

Our condolences go out to Joe’s family.  Arrangements and a guest book can be found at: https://www.devolfuneralhome.com/Funerals-and-Obituaries-in-Washington-DC/Charles-Joseph-O-Mara

 In lieu of flowers, donations to the Pediatric Congenital Heart Association http://conqueringchd.org/ or Children’s Hospital of Michigan Foundation http://chmfoundation.org/ would be appreciated.

Alternative Security Program Workshop

On Thursday, May 2 NAEGA and the National Grain and Feed Association (NGFA) hosted an annual workshop of Alternative Security Program (ASP) organizations with the U.S. Coast Guard (USCG). The ASP is an alternative way to comply with Maritime Transportation Safety Act (MTSA) regulations that allows participating organizations to develop alternative security plans approved by USCG. All NAEGA members and their facilities are invited to participate in the NAEGA/NGFA ASP. If you are interested in joining the ASP, please contact Ryan.

This year’s workshop covered ongoing issues of interest to NAEGA/NGFA ASP members, including cybersecurity, drone regulation, seafarers access, chemical regulation and security, TWIC card changes and reader rule implementation, and cruise ship security.

Of particular importance to NAEGA/NGFA ASP members and facilities is the newly finalized seafarers access regulation. Finalized on April 1, the seafarer’s access rule requires owners or operators of a maritime facility regulated by MTSA to implement a system providing seafarers, pilots and representatives of seafarers’ welfare and labor organizations with access between vessels moored at the facility and the facility gate in a timely manner and at no cost to the seafarer or other individuals. Currently, USCG will begin implementing the rule on the following schedule:

NAEGA/NGFA ASP Renewal

Over the next few months NAEGA and NGFA will be conducting outreach to ASP users as we begin to consider updates and changes to the ASP ahead of its necessary renewal date in August 2020. The NAEGA/NGFA ASP is renewed every five years, and this process allows us to amend and modernize provisions within the ASP as the security environment evolves. All ASP’s are ultimately approved by the USCG. This cycle, we anticipate that the NAEGA/NGFA ASP will need to incorporate new provisions regarding cybersecurity and seafarer access.

ASP users should keep an eye out for an email from NAEGA regarding participation in upcoming outreach sessions.

NAEGA and IGTC Mission to London, Geneva and Brussels

A trip report is now available for Katy Lee and Gary C. Martin’s travel to Brussels, Geneva, and London in March 2019. Activities included the following:

• In Brussels, Katy and Gary joined a delegation of 24 grain trade leaders discuss issues related to Plant Breeding Innovation and communicate IGTC priorities with European Union delegates.
• In Geneva, they carried out vital administrative and governance actions related to IGTC.
• In London, Katy and Gary represented the grain trade at the Market Conditions Committee meeting of the International Grains Council and attended the second meeting of the Gafta Trade Association Forum.

A trip report for this mission can be found here.

IGTC Newsletter

The latest IGTC newsletter is now available! This edition features a report on the MRL Policy Teams outreach at the World Trade Organization. and  a preview of upcoming IGTC events in Switzerland, China and Mexico.

View the latest newsletter here.

IFA Production and International Trade Conference

A trip report is now available for Katy Lee’s travel to London, UK in March 2019. In London, Katy participated in the International Fertilizer Association’s Production and International Trade Conference, where she led a presentation on “opportunities, policies and international rules-based trading systems”. During her time in London Katy also participated in meetings in the meetings with IGTC stakeholders and potential members.

A trip report for this mission can be found here.

Treated Seeds

Members can find more resources on treated seed manage here:

• The American Seed Trade Association and Crop-Life America “Guide to Seed Treatment Stewardship”, an industry-wide initiative to promote the safe handling and management of treated seed.  The purpose of the Guide is to provide farmers and seed companies with critical information and up-to-date guidelines for managing treated seed effectively to further minimize the risk of exposure to non-target organisms. We encourage you to visit the Guide website.
• The National Grain and Feed Association (NGFA) has “Treated Seed Guidance” which outlines best practices for handling treated seeds and proper disposal of treated seeds.  The best practices for preventing treated seeds from being mixed with grain is to handle treated seeds with separate and dedicated equipment.  Disposal of treated seeds should be done in compliance with state and local regulations.  Contacts for waste disposal can be found at: https://www.epa.gov/learn-issues/learn-about-waste
• The U.S. soybean family notes that “because U.S. farmer compliance is critical to avoid disruption of U.S. soybean exports to overseas markets, disposal recommendations were included in the ‘Treated Seed Disposal’ section of the Pesticide Environmental Stewardship website of the Center for Integrated Pest Management”. It can be found at:

http://pesticidestewardship.org/disposal/Pages/treatedseeddisposal.aspx.

A copy of the letter NAEGA sent can be found here.