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  • OFAC sanctions Venezuela’s military counterintelligence agency

    Financial Crimes

    On July 11, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions, pursuant to Executive Order 13850, against the Government of Venezuela’s General Directorate of Military Counterintelligence (DGCIM) for operating in the country’s defense and security sector. According to OFAC, the DGCIM has been involved in human rights abuses and the “politically motivated” arrest and death of a Venezuelan Navy captain. As a result of the sanctions, all property and interests in property of the sanctioned entity or of other entities “that are owned, directly or indirectly, 50 percent or more” by the sanctioned entity “that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC.” U.S. persons are also generally prohibited from entering into transactions with these entities. Furthermore, OFAC also referred financial institutions to Financial Crimes Enforcement Network advisories FIN-2019-A002, FIN-2017-A006, and FIN-2018-A003 for further information concerning the efforts of Venezuelan government agencies and individuals to use the U.S. financial system and real estate market to launder corrupt proceeds, as well as human rights abuses connected to corrupt foreign political figures and their financial facilitators.

    Financial Crimes Department of Treasury OFAC Sanctions Venezuela Of Interest to Non-US Persons

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  • OFAC sanctions Iranian-backed Hizballah officials

    Financial Crimes

    On July 9, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13224 against three Iranian-backed Hizballah political and security figures for “exploit[ing] Lebanon’s financial and security elements” in furtherance of Hizballah’s and Iran’s activities in support of terrorists and acts of terrorism. As a result of the sanctions, “all property and interests in property of these targets that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC.” OFAC notes that its regulations “generally prohibit” U.S. persons from participating in transactions with the designated individuals. The designated individuals are also subject to secondary sanctions pursuant to the Hizballah Financial Sanctions Regulations, which implement the Hizballah International Financing Prevention Act of 2015, and allow OFAC the authority to “prohibit or impose strict conditions on the opening or maintaining in the United States of a correspondent account or a payable-through account by a foreign financial institution that knowingly facilitates a significant transaction for Hizballah, or a person acting on behalf of or at the direction of, or owned or controlled by, Hizballah.”

    Financial Crimes Department of Treasury OFAC Sanctions Iran Of Interest to Non-US Persons

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  • OFAC sanctions Cuban oil company for facilitating Maduro regime

    Financial Crimes

    On July 3, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions against Cuban state-run oil import and export company for continuing to provide support to the Maduro regime by the importation of oil from Venezuela. The sanctions are pursuant to Executive Order 13850. OFAC alleges that the state-run company has been the recipient of oil from Venezuela and has expanded its operations to include non-traditionally traded oil products. As a result of the sanctions, “all property and interests in property of these individuals, and of any entities that are owned, directly or indirectly, 50 percent or more by such individuals, that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC.” OFAC notes that its regulations “generally prohibit” U.S. persons from participating in transactions with these individuals and entities.

    Additionally, the announcement notes that OFAC is delisting an oil tanking company in recognition of the company’s actions to ensure that its vessels are not complicit in supporting the Maduro regime. As a result of the delisting, all property and interest of the company is now unblocked and lawful transactions involving U.S. persons are no longer prohibited.

    Financial Crimes Department of Treasury Of Interest to Non-US Persons OFAC Executive Order Sanctions Venezuela Cuba

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  • OFAC sanctions Maduro regime officials in Venezuela

    Financial Crimes

    On June 27 and 28, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated two Maduro regime officials and the son of Maduro for engaging in significant corruption and fraud to the detriment of the people of Venezuela. Specifically, OFAC designated the two regime officials pursuant to Executive Order (E.O.) 13692, for having previously received bribes from two Venezuelan businessmen in exchange for awarding contracts for expensive equipment to maintain Venezuelan electrical infrastructure, which were incompatible with the Venezuelan electrical system. Continued corruption and mismanagement resulted in persistent countrywide blackouts, limiting the people’s access to basic goods, services, and potable water supplies, among other things.

    Additionally, pursuant to E.O. 13692, OFAC designated the son of Maduro for being a current or former official of the Government of Venezuela and a member of Venezuela’s illegitimate National Constituent Assembly, “which seeks to rewrite the Venezuelan constitution and dissolve Venezuelan state institutions, [and] was created through an undemocratic process instigated by Maduro’s government to subvert the will of the Venezuelan people.”

    Financial Crimes Of Interest to Non-US Persons Venezuela Sanctions Executive Order Department of Treasury

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  • OFAC amends Venezuela-related general licenses; temporarily extends two Ukraine-related general licenses

    Financial Crimes

    On June 26, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced General License (GL) 13B, which supersedes and replaces GL 13A. GL 13B expires on October 25. Additionally, OFAC extended the expiration date to November 8 of two Ukraine-related GLs by issuing GL 13L, which supersedes GL 13K, and GL 15F, which supersedes GL 15 E. OFAC also noted that GL 15F includes a new authorization for certain safety-related activity.

    Visit here for continuing InfoBytes coverage of actions related to Venezuela, and here for actions related to Ukraine.

    Financial Crimes Department of Treasury OFAC Sanctions Venezuela Ukraine

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  • FATF establishes binding measures on virtual currency regulation

    Financial Crimes

    On June 21, the Secretary of the U.S. Department of the Treasury issued a statement confirming that FATF members agreed to regulate and supervise virtual asset financial activities and related service providers. On the same day, FATF issued a statement noting that it “adopted and issued an Interpretive Note to Recommendation 15 on New Technologies (INR. 15) that further clarifies the FATF’s previous amendments to the international Standards relating to virtual assets and describes how countries and obliged entities must comply with the relevant FATF Recommendations to prevent the misuse of virtual assets for money laundering and terrorist financing and the financing of proliferation.” As previously covered by InfoBytes, in October 2018, FATF urged all countries to take measures to prevent virtual assets and cryptocurrencies from being used to finance crime and terrorism and updated The FATF Recommendations to add new definitions for “virtual assets” and “virtual asset service providers” and to clarify how the recommendations apply to financial activities involving virtual assets and cryptocurrencies.

    According to FATF announcement, INR. 15 establishes “binding measures,” which require countries to, among other things, (i) assess and mitigate risks associated with virtual asset activities and service providers; (ii) license or register service providers and subject them to supervision; (iii) implement sanctions and other enforcement measures when service providers fail to comply with an anti-money laundering/combating the financing of terrorism (AML/CFT) obligation; and (iv) ensure that service providers implement the full range of AML/CFT preventive measures under the FATF Recommendations, including customer due diligence, record-keeping, suspicious transaction reporting, and screening all transactions for compliance with targeted financial sanctions.

    Financial Crimes Department of Treasury Of Interest to Non-US Persons FATF Fintech Virtual Currency Cryptocurrency

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  • President Trump imposes new sanctions on Iran; OFAC announces designations

    Financial Crimes

    On June 24, President Trump issued Executive Order (E.O.) 13876, “Imposing Sanctions with Respect to Iran,” which: (i) imposes sanctions on Iran’s Supreme Leader’s Office (SLO); and (ii) targets persons appointed to certain official or other positions by the Supreme Leader and/or his office for allegedly taking actions to “destabilize the Middle East, promote international terrorism, and advance Iran’s ballistic missile program, and Iran’s irresponsible and provocative actions in and over international waters.” Among other things, E.O. 13876 authorizes the Secretaries of Treasury and State to impose sanctions on a foreign financial institution if it is determined that it has knowingly conducted or facilitated any significant financial transactions in these sectors, or for or on behalf of a blocked person. These sanctions would prohibit the opening of, or impose strict conditions on maintaining, a correspondent account or payable-through account by such foreign financial institutions in the United States.

    On the same day, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated eight senior commanders of the Islamic Revolutionary Guard Corps (IRGC) pursuant to E.O. 13224, which “provides a means by which to disrupt the financial support network for terrorists and terrorist organizations.” According to OFAC, the sanctions are meant to reinforce the President’s newly issued E.O. 13876. As a result of the designations, “all property and interests in property of these targets that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC.” OFAC noted that persons who engage in transactions with the designated individuals and entities may be exposed to sanctions themselves or subject to enforcement action.

    Financial Crimes Department of Treasury Of Interest to Non-US Persons OFAC Executive Order Sanctions Iran

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  • OFAC targets Russian facilitators of illicit North Korean transactions

    Financial Crimes

    On June 19, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced its decision to sanction a Russian financial entity, pursuant to Executive Order 13382, for allegedly “having provided, or attempted to provide, financial, material, technological, or other support for, or goods or services” on behalf of an entity that is owned and controlled by North Korea’s primary foreign exchange bank. According to OFAC, since at least 2017 and continuing through 2018, the Russian entity has provided multiple accounts to the North Korean entity, which has “enabled North Korea to circumvent U.S. and UN sanctions to gain access to the global financial system in order to generate revenue for the Kim regime’s nuclear program.” Pursuant to OFAC’s sanctions, all property and interests in property of the designated persons within U.S. jurisdiction must be blocked and reported to OFAC. OFAC notes that its regulations “generally prohibit” U.S. persons from participating in transactions with these individuals and entities.

    Financial Crimes Russia North Korea Sanctions Department of Treasury OFAC

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  • OFAC amends the Reporting, Procedures and Penalties Regulations

    Agency Rule-Making & Guidance

    On June 20, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a final interim rule amending its Reporting, Procedures and Penalties Regulations, which set forth the standard reporting and recordkeeping requirements, license application, and other procedures relevant to the economic sanctions programs administered by OFAC. Among other things, the final interim rule: (i) expands the information that must be included in reports on blocked property and rejected transactions; (ii) includes details on the information that must be included when OFAC requires a report that property has been unblocked; (iii) revises procedures for (a) reporting on rejected transactions; (b) licensing of otherwise prohibited transactions; and (c) releasing blocked funds; and (iv) clarifies rules governing the availability of information under the Freedom of Information Act. Importantly, the revisions clarify that all U.S. persons must report transactions that have been rejected for sanctions compliance reasons. Previously, the requirement was thought to apply only to U.S. financial institutions. The final interim rule will take effect upon publication in the Federal Register, which is scheduled for June 21.

     

    Agency Rule-Making & Guidance OFAC Of Interest to Non-US Persons Department of Treasury

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  • OFAC sanctions entity and two individuals for trafficking weapons to IRGC-QF and facilitating sanctions evasion

    Financial Crimes

    On June 12, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed sanctions on a resource trading company and its two Iraqi associates, for trafficking “hundreds of millions of dollars’ worth of weapons” to the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) and facilitating access to the Iraqi financial system to evade sanctions.

    According to OFAC, the sanctions were issued pursuant to Executive Order 13224, which “provides a means by which to disrupt the financial support network for terrorists and terrorist organizations.” As a result, “all property and interests in property of these targets that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC.” OFAC noted that persons who engage in transactions with the designated individuals and entities may be exposed to sanctions themselves or subject to enforcement action. Moreover, OFAC warned foreign financial institutions that, unless an exemption applies, they may be subject to U.S. sanctions if they knowingly facilitate significant transactions for any of the designed individuals or entities.

    Financial Crimes Department of Treasury OFAC Executive Order Sanctions Venezuela

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