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Financial Services Law Insights and Observations

OFAC sanctions over 40 individuals and entities in nine countries

Financial Crimes Of Interest to Non-US Persons Department of Treasury OFAC Sanctions OFAC Designations OFAC SDN List

Financial Crimes

On December 9, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions against 40 individuals and entities that are connected to corruption or human rights abuse across nine countries, in recognition of International Anti-Corruption Day and Human Rights Day. According to OFAC, throughout 2022, Treasury “took numerous actions to promote accountability for human rights abusers and corrupt actors across the world, including sanctions on dozens of individuals and entities including in the Western Balkans, Belarus, Liberia, Guatemala, the Russian Federation, Burma, and Iran. Treasury utilized various tools and authorities — including Executive Order 13818, which builds upon and implements the Global Magnitsky Human Rights Accountability Act — to demonstrate the U.S. government’s focus on promoting respect for human rights and countering corruption.” As a result of the sanctions, all transactions by U.S. persons or in the U.S. that involve any property or interests in property of designated or otherwise blocked persons are generally prohibited. Additionally, “any entities that are owned, directly or indirectly 50 percent or more by them, individually, or with other blocked persons, that are in the United States or in the possession or control of U.S. persons, must be blocked and reported to OFAC.” U.S. persons are generally prohibited from engaging in any dealings involving the property or interests in property of blocked or designated persons, unless exempt or authorized by a general or specific OFAC license.