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OFAC sanctions four individuals for human rights violations in Iraq
On July 18, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13818 against two militia figures and two former Iraqi governors for alleged human rights abuses or corruption violations of the Global Magnitsky Human Rights Accountability Act. According to OFAC, the four individuals committed the corruption-and abuse-related actions “in areas where persecuted religious communities are struggling to recover from the horrors inflicted on them by ISIS.” As a result of the 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.
OFAC sanctions senior member of Hizballah operation
On July 19, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13224 against a senior Hizballah operative allegedly connected to the planning, coordination, and execution of terrorist attacks outside of Lebanon. According to OFAC, the action is part of the Treasury Department’s continued attempts to disrupt “the full range of Hizballah’s illicit financial and facilitation activities.” As a result of the sanctions, “all property and interests in property of this target 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 person. The designated individual is 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.”
OFAC sanctions Venezuela’s military counterintelligence agency
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.
OFAC sanctions Iranian-backed Hizballah officials
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.”
OFAC sanctions Cuban oil company for facilitating Maduro regime
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.
OFAC sanctions Maduro regime officials in Venezuela
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.”
OFAC amends Venezuela-related general licenses; temporarily extends two Ukraine-related general licenses
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.
President Trump imposes new sanctions on Iran; OFAC announces designations
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.
OFAC targets Russian facilitators of illicit North Korean transactions
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.
OFAC sanctions entity and two individuals for trafficking weapons to IRGC-QF and facilitating sanctions evasion
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.