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Financial Services Law Insights and Observations

OFAC Updates: New Sanction Designations and Additions to Specially Designated Nationals List

Financial Crimes OFAC Sanctions

Financial Crimes

In May, OFAC announced implementation of sanctions against several entities and individuals designated for, among others, materially assisting, sponsoring, or providing financial support to certain foreign entities. In addition, OFAC updated its list of Specially Designated Nationals.

Pakistan-Based ISIS Financial Facilitators. On May 11, OFAC imposed sanctions against three Pakistani individuals and one entity for their roles in assisting ISIS’s financial networks and their “connections with terrorist groups that are a direct threat to the security of both the [U.S.] and Pakistan.” The designations block the individuals and entity—each of whom has been designated as providing the identified networks with material and financial support—from participating in the global financial system, and further state that “all property and interests in property . . . subject to U.S. jurisdiction are blocked, and U.S. persons are generally prohibited from engaging in transactions with” those listed.

Syrian Government Supporters. On May 16, OFAC announced it was taking action against five individuals and five entities in response to the Syrian Government’s continued acts of violence committed against its own citizens. The sanctions came as a reaction to three Executive Orders: (i) E.O. 13572—targeting persons responsible for human rights abuses in Syria, their supporters, and supporters of senior officials or certain activities related to public corruption; (ii) E.O. 13582—targeting the Government of Syria and its supporters; and (iii) E.O. 13382—targeting proliferators of weapons of mass destruction and their supporters. The new sanctions prohibit transactions by U.S. persons with those listed and “any property or interest in property of the identified persons in the possession or control of U.S. persons or within the United States must be blocked.”

Yemen-Based Financial Facilitators and Arms Trafficker. On May 19, OFAC imposed sanctions against two Yemen-based financial facilitators for their roles in assisting al-Qa’ida leaders in the Arabian Peninsula. The designations block the individuals, both of whom were designated as engaging in actions through weapon trafficking, from the global financial system, and further state that “all property and interests in property . . . subject to U.S. jurisdiction are blocked, and U.S. persons are generally prohibited from engaging in transactions with” the identified individuals.

Foreign Narcotics Kingpin Sanctions. On May 19, OFAC made additions to the Specially Designated Nationals (SDN) list, which designates individuals and companies who are prohibited from dealing with the U.S. and whose assets are blocked. Transactions are prohibited if they involve transferring, paying, exporting, or otherwise dealing in the property or interest in property of an entity or individual on the SDN list. Additions to the list were made under the Foreign Narcotics Kingpin Sanctions Regulations against two two Peruvian individuals and three Peruvian entities.