On October 24, 2018, Office of Foreign Assets Control (OFAC) announced that, together with the Department of State, it is extending the Belarus General License 2F’s expiration date. The general license authorizes transactions with certain entities in Belarus pursuant to Executive Order 13405. However, the general license does not authorize the release of blocked property. The expiration date for the general … Continue Reading
On October 12 and October 19, 2018, Office of Foreign Assets Control (OFAC) extended the expiration date of certain Ukraine-related General Licenses. Specifically, OFAC issued General License 13E and 13F, Authorizing Certain Transactions Necessary to Divest or Transfer Debt, Equity, or Other Holdings in Certain Blocked Persons, which extend the deadline for certain transactions with GAZ Group and with RUSAL … Continue Reading
On October 16, 2018, OFAC announced sanctions “against a vast network of businesses providing financial support to the Basij Resistance Force (Basij), a parliamentary force subordinate to Iran’s Revolutionary Guard Corps (IRGC).” According to OFAC, the Basij militia recruits, trains and deploys child soldiers to fight in IRGC conflicts across the region. Bonyad Taavon Basij, an Iran-based network, is comprised of … Continue Reading
On October 5, 2018, the US Department of the Treasury, Office of Foreign Assets Control (OFAC) announced an agreement with JPMorgan Chase Bank, N.A. (JPMC) to settle potential civil liability arising from 87 apparent violations of the Cuban Assets Control Regulations, the Iranian Transactions and Sanctions Regulations, and the Weapons of Mass Destruction Proliferators Sanctions Regulations. According to OFAC, “the transactions … Continue Reading
On September 21, 2018, OFAC extended certain Ukraine-related general licenses. OFAC issued General License No. 13D authorizing certain transactions necessary to divest or transfer debt, equity, or other holdings in listed blocked persons. OFAC also issued General Licenses No. 14A and 16A, which authorize certain activities necessary to the maintenance or wind down of operations or existing contracts with 1) United … Continue Reading
On 1 March, the Office of Foreign Assets Control (OFAC) announced the amendment and reissuance in its entirety of the North Korea Sanctions Regulations, 31 C.F.R. part 510. These regulations were updated to reflect and incorporate the North Korea-related executive orders issued in recent years and additional changes to North Korea-related laws, specifically the North Korea Sanctions and Policy Enhancement … Continue Reading
On 6 April, the Office of Foreign Assets Control (OFAC) designated seven Russian oligarchs, 12 companies they own or control, 17 senior Russian government officials and a state-owned Russian weapons trading company and its subsidiary, a Russian bank, pursuant to Executive Order 13661, 13662 and the Countering America’s Adversaries Through Sanctions Act (CAATSA). According to the US Department of Treasury, … Continue Reading
On 6 December 2017, OFAC announced a settlement agreement for US$1,220,400 with DENTSPLY SIRONA INC. (DSI), a US company incorporated in Delaware, the successor in interest to DENTSPLY International Inc. (DII), in connection with 37 violations of the Iranian Transactions and Sanctions Regulations between November 2009 and July 2012. According to the OFAC press release, … Continue Reading
On 29 January 2018, OFAC announced that it released five reports to Congressional Committees pursuant to the Countering America’s Adversaries Through Sanctions Act of 2017 (CAATSA). The reports include (1) Section 241: Report on Senior Foreign Political Figures and Oligarchs in the Russian Federation; (2) Section 104(e): Report on Contributions to Iran’s Ballistic Missile Program; … Continue Reading
On 24 January 2018, OFAC designated nine entities, 16 individuals and six vessels “in response to North Korea’s ongoing development of weapons of mass destruction (WMD) and continued violations of United Nations Security Council Resolutions”. The designations “target agents of the Kim regime financing or otherwise supporting North Korea’s WMD programs and other illicit businesses”.… Continue Reading
On 4 January 2018, OFAC designated five Iran-based entities “subordinate to a key element of Iran’s ballistic missile program”. OFAC designated these entities pursuant to EO 13382 for being owned or controlled by Iran’s Shahid Bakeri Industrial Group (SBIG). The SBIG is listed in the Annex to EO 13382 and is currently sanctioned by the … Continue Reading
On 5 January 2018, OFAC designated four current or former Venezuelan government offcials pursuant to EO 13692 for their alleged role in undermining electoral processes, media censorship, or corruption in government-administered food programs in Venezuela. Included among the individuals designated was Rodolfo Clemente Marco Torres, who is an External Director on the Board of Directors … Continue Reading
OFAC announced new regulations implementing certain provisions of the Sergei Magnitsky Rule of Law Accountability Act of 2012 (Magnitsky Act) on 20 December 2017. The regulations became effective upon publication in the Federal Register on December 21. OFAC also announced the addition of five designations to the SDN List pursuant to the Magnitsky Act.… Continue Reading
On 20 December 2017, President Trump issued EO 13818, authorising the imposition of financial sanctions against designated persons determined to be directly or indirectly engaged in certain human rights abuses or corrupt acts around the world. OFAC subsequently released new Frequently Asked Questions and published updated designations.… Continue Reading
Effective 28 December 2017, US Treasury’s Office of Foreign Assets Control (OFAC) amended the Iraq Stabilization and Insurgency Sanctions Regulations, 31 CFR part 576, to implement Executive Order (EO) 13668 (“Ending Immunities Granted to the Development Fund for Iraq and Certain Other Iraqi Property and Interests in Property Pursuant to Executive Order 13303, as amended”). … Continue Reading
On 17 November, OFAC announced a settlement agreement with BCC Corporate SA (BCCC), a Belgium-based credit card issuer and corporate service company, in connection with 1,818 violations of the Cuban Assets Control Regulations occurring between April 2009 and February 2014. During this time, BCCC was a wholly owned subsidiary of Alpha Card Group, which in … Continue Reading
OFAC and US Department of Commerce’s Bureau of Industry and Security (BIS) have each issued new regulations implementing President Trump’s June 2017 National Security Presidential Memorandum on Cuba (the “Cuba NSPM”). On 9 November, OFAC published amendments to the Cuban Assets Control Regulations (31 C.F.R. Part 515) in the Federal Register. The amendments implement the … Continue Reading
The US Department of Treasury’s Office of Foreign Assets Control (OFAC) has published two new Frequently Asked Questions (FAQ) concerning economic sanctions adopted in August against the Government of Venezuela, under Executive Order (EO) 13808. The first FAQ explains the treatment of Petroleos de Venezuela, S.A. (PdVSA), a state-owned entity, under EO 13808. The second … Continue Reading
On 13 October, President Trump announced the results of his administration’s review of the US’ Iran policy, indicating at the same time that he would not “certify” to Iran’s compliance with the Joint Comprehensive Plan of Action (JCPOA) agreement. Since President Trump took office, he has “certified” to Iran’s compliance twice, so this is the first time that he did … Continue Reading
On 20 September, President Trump issued an Executive Order (EO) authorising broad new economic sanctions against North Korea, by targeting those dealing with the country. The Order, EO 13810, adds to the existing US embargo of North Korea by authorising the US Treasury’s Office of Foreign Assets Control (OFAC) to impose blocking sanctions against any person found to be participating … Continue Reading
Sudan Sanctions In 1997, the US imposed a comprehensive trade and investment embargo against Sudan. In January 2017, i.e., in the closing days of the Obama Administration, President Obama announced a six-month suspension of US economic sanctions, citing ongoing dialogue with the Sudanese government and the government’s progress in achieving milestones agreed upon in those negotiations. Specifically, the Obama Administration … Continue Reading
On 8 June 2017, the Office of Foreign Assets Control (OFAC) announced a settlement agreement with American Honda Finance Corporation (AHFC), a California company, under which AHFC agreed to pay US$87,255 to settle apparent violations of Cuba sanctions. Separately, on 26 June 2017, OFAC announced a settlement agreement with American International Group, Inc. (AIG), a Delaware company headquartered in New York, … Continue Reading
On 29 June 2017, the US Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a proposed rule that would designate China’s Bank of Dandong to be a foreign financial institution of primary money laundering concern under Section 311 of the USA PATRIOT Act. The measure responds to findings that the bank used the US financial system to facilitate millions of dollars … Continue Reading
In June 2017, the Office of Foreign Assets Control (OFAC) and the US Commerce Department’s Bureau of Industry and Security (BIS) imposed coordinated sanctions against two entities from the Crimea Region of Ukraine and eight entities from Russia. OFAC added each entity to the OFAC List of Specially Designated Nationals (SDN List) and Block Persons under the executive orders implemented … Continue Reading
