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OFAC sanctions Iranian bank officials, Iraqi bank, and others for moving millions of dollars to Hizballah
On May 15, U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced it was imposing sanctions on the governor and a senior official of the Central Bank of Iran, an Iraqi bank and its chairman, and a key Hizballah official, for allegedly funneling millions of dollars on behalf of the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) to Hizballah. Pursuant to Executive Order 13224, which “provides a means by which to disrupt the financial support network for terrorists and terrorist organizations by authorizing the U.S. government to designate and block the assets of foreign individuals and entities that commit, or pose a significant risk of committing, acts of terrorism,” the individuals and entities were designated as Specially Designated Global Terrorists. The actions, which follow a May 10 action taken against individuals and entities who materially assisted in the conversion of millions of U.S. dollars to fund IRGC-QF’s malignant activities, “seek to stifle Iran’s ability to abuse the U.S. and regional financial systems.”
However, OFAC clarified that sanctions on the officials of the Central Bank of Iran do not extend to the bank itself. Following President Trump's decision to cease participation by the U.S. government in the Joint Comprehensive Plan of Action, sanctions on the bank will be re-imposed August 7, and on November 5, additional sanctions will be re-imposed on persons knowingly engaging in certain significant transactions with the Central Bank of Iran.
Visit here for additional InfoBytes coverage on Iranian sanctions.
OFAC adds Iranians to Specially Designated Nationals List
On May 10, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) made additions to the Specially Designated Nationals List under the Iranian Financial Sanctions Regulations and Global Terrorism Sanctions Regulations. OFAC’s additions to the designations identify nine individuals and entities that materially assisted in converting millions of U.S. dollars to fund the Islamic Revolutionary Guard Corps-Qods Force’s malignant activities. As a result, all assets belonging to the identified individuals and entities subject to U.S. jurisdiction are blocked and must be reported to OFAC, and U.S. persons are generally prohibited from dealing with them.
OFAC adds Venezuelans to Specially Designated Nationals List
On May 7, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) made additions to the Specially Designated Nationals List under the Foreign Narcotics Kingpin Designation Act. OFAC’s additions to the list include a former Venezuelan financial intelligence service official, two of his aides, and 20 companies located in Venezuela and Panama, owned or controlled by the three individuals. The designations identify persons who have materially assisted in, or provided financial or technological support for or to, the former official’s international narcotics trafficking activities, which include the laundering of narcotics proceeds and other illicit funds. As a result, all assets belonging to the identified individuals and entities subject to U.S. jurisdiction are blocked and must be reported to OFAC, and U.S. persons are generally prohibited from dealing with them.
See here for continuing InfoBytes coverage of Venezuelan actions.
FINRA releases new Sanctions Guidelines revisions
On May 2, FINRA issued a notice revising its Sanction Guidelines to reflect recent changes to General Principle No. 2, which instructs adjudicators “to consider customer-initiated arbitrations that result in adverse arbitration awards or settlements” in addition to the more traditional disciplinary history when assessing sanctions. FINRA Regulatory Notice 18-17 states that if an adjudicator determines that a “pattern of causing harm” to investors or market integrity exits, or a respondent demonstrates a disregard to regulatory requirements, then more stringent sanctions should be considered.
Revisions to the Sanctions Guidelines will apply to all complaints filed in FINRA’s disciplinary system beginning June 1.
OFAC issues new Ukraine-/Russia-related General Licenses and FAQs
On May 1, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued Ukraine-/Russia-related General License 12B (GL 12B) authorizing specified wind-down activities, which would be otherwise prohibited by Ukraine-related Sanctions Regulations, through June 5. According to a Treasury announcement, GL 12B—which replaces and supersedes General License 12A in its entirely—permits “originating and intermediary U.S. financial institutions to process funds transfers that they would otherwise block to an account held by a blocked U.S. person at a U.S. financial institution,” and allows the release of “such funds for authorized maintenance and wind-down purposes.”
The same day, OFAC also issued Ukraine-/Russia-related General License 13A (GL 13A) to replace and supersede General License 13 (GL 13) in its entirety. (See previous InfoBytes coverage on GL 13 here.) GL 13A authorizes certain divestiture transactions with specified blocked persons to a non-U.S. person, and allows the facilitation of transfers of debt, equity, or other holdings involving listed blocked persons, including entities owned 50 percent or more and issued by the named persons. GL 13A is effective through June 6.
OFAC also released three new FAQs and published updated FAQs related to these general licenses.
Visit here for additional InfoBytes coverage on Ukraine/Russian sanctions.
Treasury issues general license to extend wind-down period for sanctioned Russian aluminum producer
On April 23, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued General License 14 (GL 14) to extend the grace period for specified wind-down activities involving a Russian aluminum producer sanctioned earlier this month. As previously covered in InfoBytes here, the April 6 sanctions—issued pursuant to the Countering America’s Adversaries Through Sanctions Act of 2017—allowed U.S. persons until May 7 to wind down operations involving identified blocked persons. According to Treasury’s press release, GL 14’s new October 23 deadline provides Treasury time to consider the aluminum producer’s petition for delisting given the impact the April 6 sanctions have had on U.S. partners and allies. Additionally, Treasury stated that “OFAC will not impose secondary sanctions on non-U.S. persons for engaging in the same activity involving [the aluminum producer] or its subsidiaries that General License 14 authorizes U.S. persons to engage in.”
The same day, OFAC also issued an amended General License 12A to reflect the authorization in GL 14, and released several new FAQs addressing authorizations and limitations under GL 14.
Visit here for additional InfoBytes coverage on Ukraine/Russian sanctions.
OFAC sanctions Russian oligarchs and government officials; releases new general licenses and updated FAQs
On April 6, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced its decision to sanction seven Russian oligarchs along with 12 companies they own or control, 17 senior Russian government officials, and a state-owned Russian weapons trading company and its Russian bank subsidiary, pursuant to the Countering America’s Adversaries Through Sanctions Act of 2017 (CAATSA) and Executive Orders 13661, 13662, and 13582. In a foreign policy statement released the same day, President Trump explained that the identified persons placed on the Specially Designated Nationals (SDNs) and Blocked Persons List engaged in actions that have reportedly contributed to “advancing Russia’s malign activities,” including (i) profiting from “Russia's destabilizing activities”; (ii) election meddling; (iii) undermining U.S. cybersecurity; (iv) engaging in weapons proliferation; (v) continuing to occupy Crimea; (vi) instigating violence in eastern Ukraine; and (vii) providing military equipment and support for the Government of Syria's continued attacks against Syrian citizens. Pursuant to OFAC’s sanctions, all property or interests in property of the designated persons along with any other entity owned 50 percent or more by one or more designated persons that is within U.S. jurisdiction are blocked, and U.S. persons are “generally prohibited” from participating in transactions with these individuals and entities. Additionally, “non-U.S. persons could face sanctions for knowingly facilitating significant transactions for or on behalf of the individuals or entities blocked today.”
The same day, OFAC issued two Ukraine-/Russia-related general licenses to “minimize immediate disruptions to U.S. persons, partners, and allies.” General License 12 authorizes through June 5 certain activities necessary to “wind down” operations, contracts, or agreements in effect prior to April 6 involving specified blocked persons. General License 13 authorizes through May 7 divestiture transactions with certain blocked persons to a non-U.S. person, as well as the facilitation of transfers of debt, equity, or other holdings involving listed blocked persons by a non-U.S. person to another non-U.S. person. OFAC also released eight new FAQs related to this action and published one updated FAQ related to CAATSA.
Visit here for additional InfoBytes coverage on Ukraine/Russian sanctions.
OFAC sanctions Iranian nationals for malicious cyberattacks
On March 23, the Treasury Department’s Office of Foreign Assets Control (OFAC), in coordination with the DOJ, imposed additional sanctions on an Iranian entity and 10 Iranian nationals, pursuant to Executive Order 13694, for conducting malicious cyberattacks against hundreds of U.S. and third-country universities for private financial gain. Nine of the identified individuals are connected to the Mabna Institute and are accused of misappropriating “economic resources or personal identifiers” to aid Iran’s Islamic Revolutionary Guard Corps. Pursuant to these sanctions, all property or interests in property of the designated persons within U.S. jurisdiction are blocked, and U.S. persons are “generally prohibited” from participating in transactions with these individuals and entities. Additionally, as reported in a DOJ press release, the nine Iranians have also been indicted for engaging in malicious cyber-enabled activities. A tenth Iranian national was sanctioned for engaging in cyber-related actions targeting a U.S. media company.
Visit here for additional InfoBytes coverage on Iranian sanctions.
Treasury adjusts for inflation maximum civil monetary penalties assessed under OFAC sanction regulations
On March 19, the U.S. Treasury Department published a final rule in the Federal Register that adjusts for inflation the maximum amount of civil monetary penalties that may be assessed by the Treasury’s Terrorism Risk Insurance Program, Office of Foreign Assets Control, and Financial Crimes Enforcement Network for violations of laws administered by those agencies. The rule became effective immediately.
OFAC expands Russian sanctions in connection with election interference and cyber attacks
On March 15, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced its decision to sanction an additional five entities and 19 individuals, pursuant to Countering America’s Adversaries Through Sanctions Act of 2017 (CAATSA) and Executive Order 13694 (E.O. 13694). The CAATSA sanctions target “cyber actors” who carried out cyber attacks on behalf of the Russian government, while E.O. 13694 designations target entities and individuals who interfered with the 2016 U.S. election. Pursuant to OFAC’s sanctions, all property or interests in property of the designated persons within U.S. jurisdiction are blocked, and U.S. persons are “generally prohibited” from participating in transactions with these individuals and entities. As part of the announcement, Treasury Secretary Steven Mnuchin stated that “Treasury intends to impose additional CAATSA sanctions, informed by our intelligence community, to hold Russian government officials and oligarchs accountable for their destabilizing activities by severing their access to the U.S. financial system.”
The same day, OFAC amended General License No. 1, “Authorizing Certain Transactions with the Federal Security Service” and reissued it as “Cyber General License No. 1A” (GL 1A). OFAC also published four updated FAQs relating to the agency’s sanctions and GL 1A and CAATSA.
Visit here for additional InfoBytes coverage on Russian sanctions.