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  • OFAC sanctions additional individuals and entities connected to designated Burmese military coup leader

    Financial Crimes

    On March 10, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order (E.O.) 14014 against two individuals along with six of their companies. The individuals are the adult children of a previously designated Commander-in-Chief of the Burmese military forces (covered by InfoBytes here)—an individual OFAC claims is “the leading actor in the overthrow of Burma’s democratically elected government.” Under E.O. 14014, foreign persons may be sanctioned who are the spouses or adult children of a person whose property and interests in property are blocked. As a result of the sanctions, all property and interests in property belonging to the sanctioned individuals and entities, and “any entities that are owned, directly or indirectly, 50 percent or more by them,” subject to U.S. jurisdiction are blocked and must be 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 license.

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

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  • OFAC sanctions Mexican national linked to narcotics trafficking

    Financial Crimes

    On March 3, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to the Foreign Narcotics Kingpin Designation Act against a Mexican national “for his high-level role in facilitating drug shipments and money laundering for the Cartel de Jalisco Nueva Generacion (CJNG).” According to OFAC, the individual materially assisted in, provided financial or technological support for or to, or provided goods or services in support of, CJNG activities. The designated individual joins other previously designated businesses and individuals linked to CJNG for playing “critical roles in CJNG’s drug trafficking activities, including money laundering.” As a result of the sanctions, the designated individual’s property located in the U.S. or held by U.S. persons is blocked and must be reported to OFAC. Additionally, OFAC regulations generally prohibit U.S. persons from participating in transactions with the designated individual.

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

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  • OFAC sanctions Russian officials

    Financial Crimes

    On March 2, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order (E.O.) 13661 against seven Russian government officials in connection with the “poisoning and subsequent imprisonment of [a] Russian opposition figure.” One of the designated individuals is also being sanctioned pursuant to E.O. 13382 “for acting or purporting to act for or on behalf of, directly or indirectly, the Federal Security Service.” In conjunction with OFAC’s sanctions, the Department of State also designated several entities and persons pursuant to E.O. 13882 for “having engaged, or attempted to engage, in activities or transactions that have materially contributed to, or pose a risk of materially contributing to, the proliferation of weapons of mass destruction or their means of delivery” by Russia. As a result of the sanctions, all of the property and interests in property of the designated persons that are in the United States or in the possession or control of U.S. persons, as well as any entities that are owned 50 percent or more by the designated persons, are blocked and must be reported to OFAC. Additionally, OFAC regulations generally prohibit U.S. persons from participating in transactions with the designated persons unless exempt or otherwise authorized by an OFAC general or specific license. OFAC further warned that “any foreign person who knowingly facilitates a significant transaction or transactions for or on behalf of one of these persons risks being sanctioned.”

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

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  • OFAC sanctions key Yemeni military leaders

    Financial Crimes

    On March 2, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions against two individuals associated with the Ansarallah militia. The sanctions are taken pursuant to Executive Order 13611, which authorizes “blocking property of persons threatening the peace, security, or stability of Yemen.” As a result of the sanctions, all of the property and interests in property of the designated individuals that are in the United States or in the possession or control of U.S. persons, as well as any entities that are owned 50 percent or more by the designated individuals, are blocked and must be reported to OFAC. Additionally, OFAC regulations prohibit U.S. persons from participating in transactions with the designated individuals unless exempt or otherwise authorized by an OFAC general or specific license. OFAC specifies that the “prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any blocked person or the receipt of any contribution or provision of funds, goods, or services from any such person.”

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

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  • OFAC amends cyber-related general license and related FAQs

    Financial Crimes

    On March 2, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued cyber-related General License (GL) 1B, “Authorizing Certain Transactions with the Federal Security Service,” which authorizes certain transactions and activities that are “necessary and ordinarily incident” to the “[r]equesting, receiving, utilizing, paying for, or dealing in licenses, permits, certifications, or notifications issued or registered by the Federal Security Service for the importation, distribution, or use of information technology products in the Russian Federation,” provided certain criteria are met. OFAC also published three amended FAQs related to GL 1B (see 501, 502, and 503). Effective March 2, GL 1B supersedes and replaces GL 1A, which was issued in 2018 and covered by InfoBytes here.

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

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  • OFAC sanctions Saudis for human rights abuse

    Financial Crimes

    On February 26, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions against Saudi Arabia’s former Deputy Head of General Intelligence Presidency and Saudi Arabia’s Rapid Intervention Force in connection with the death of a Saudi journalist. The sanctions are taken pursuant to Executive Order 13818, which implements the Global Magnitsky Human Rights Accountability Act and “targets perpetrators of serious human rights abuse and corruption around the world.” As a result of the sanctions, all of the property and interests in property of the designated persons that are in the United States or in the possession or control of U.S. persons, as well as any entities that are owned 50 percent or more by the designated persons, are blocked and must be reported to OFAC. Additionally, OFAC regulations prohibit U.S. persons from participating in transactions with the designated persons unless exempt or otherwise authorized by an OFAC general or specific license.

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

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  • OFAC updates SDN List

    Financial Crimes

    On February 22, the U.S. Treasury Department’s Office of Foreign Assets Control added two entities to its Specially Designated National List pursuant to the Countering America’s Adversaries Through Sanctions Act (CAATSA). One of the added entities has been designated pursuant to CAATSA Section 235, which provides the president with the authority to, among other things, “prohibit any transfers of credit or payments between financial institutions or by, through, or to any financial institution, to the extent that such transfers or payments are subject to the jurisdiction of the United States and involve any interest of the sanctioned person” or “prohibit any United States person from investing in or purchasing significant amounts of equity or debt instruments of the sanctioned person.”

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

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  • OFAC sanctions additional individuals connected to Burmese military coup

    Financial Crimes

    On February 22, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 14014 against two individuals connected to a Burmese military coup. The sanctions build upon actions taken by OFAC earlier in the month against 10 current or former military officials as well as three Burmese entities (covered by InfoBytes here), and reaffirms the U.S.’s continued work to “promote accountability for those responsible for attempting to reverse Burma’s progress toward democracy.” As a result of the sanctions all property and interests in property belonging to the sanctioned individuals and “any entities that are owned, directly or indirectly, 50 percent or more by them, individually, or with other blocked persons,” subject to U.S. jurisdiction are blocked and must be 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 license.

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

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  • Digital payment solutions company settles with OFAC for $500k

    Financial Crimes

    On February 18, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced a $507,375 settlement with a Georgia-based payment processing solutions company for 2,102 apparent violations of multiple sanctions programs. According to OFAC’s web notice, between 2013 and 2018, the company—which offers solutions for merchants to accept digital currency as payment for goods and services—allegedly processed thousands of transactions on behalf of individuals located in sanctioned jurisdictions based on IP addresses and invoice information. Specifically, OFAC alleged that the company “received digital currency payments on behalf of its merchant customers from those merchants’ buyers who were located in sanctioned jurisdictions, converted the digital currency to fiat currency, and then related that currency to its merchants.” While OFAC noted that the company screened its direct merchants against its List of Specially Designated Nationals and Blocked Persons and conducted due diligence to ensure merchants were not located in a sanctioned jurisdiction, the company’s transaction review process allegedly failed to screen identification and location data for its merchants’ buyers, many of whom were located in Crimea, Cuba, North Korea, Iran, Sudan, and Syria. As a result, these buyers, OFAC claimed, were able to make purchases from merchants located in the U.S. and elsewhere using digital currency on the company’s platform in violation of an executive order and multiple sanctions regulations.

    In arriving at the settlement amount, OFAC considered various aggravating factors, including that the company (i) “failed to exercise due caution or care for its sanctions compliance obligations” by allowing buyers in sanctioned jurisdictions to transact with merchants despite having “sufficient information to screen those customers”; and (ii) conveyed more than $128,000 in economic benefit to individuals in OFAC sanctioned jurisdictions.

    OFAC also considered various mitigating factors, including that the company (i) had implemented certain sanctions compliance controls, including due diligence and sanctions screening; (ii) trained employees—including senior management—that signing up merchants from sanctioned jurisdictions or trading with sanctioned persons is prohibited; (iii) cooperated with OFAC’s investigation; and (iv) terminated the conduct leading to the apparent violations and undertook remedial measures to minimize the risk of similar violations from occurring in the future. The base civil monetary penalty applicable in this action is $2,255,000; however, the lower settlement amount reflects OFAC’s consideration of the general factors under the Economic Sanctions Enforcement Guidelines.

    Financial Crimes OFAC Department of Treasury Cryptocurrency Sanctions Of Interest to Non-US Persons OFAC Designations Enforcement Settlement

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  • OFAC revokes Yemen-related general licenses and designations

    Financial Crimes

    On February 16, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) revoked and archived five counter terrorism-related general licenses (GL) related to the Ansarallah designations after the U.S. Department of State determined that Ansarallah would “no longer be[] blocked pursuant to the Global Terrorism Sanctions Regulations, 31 C.F.R. part 594, the Foreign Terrorist Organizations Sanctions Regulations, 31 C.F.R. part 597, or Executive Order 13224, as amended.” Specifically, OFAC revoked GL 9, “Official Business of the United States Government,” GL 10, “Official Activities of Certain International Organizations,” GL 11, “Certain Transactions in Support of Nongovernmental Organizations’ Activities in Yemen,” GL 12, “Transactions Related to the Exportation or Reexportation of Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components or Software Updates,” and GL 13,“Authorizing Transactions Involving Ansarallah.” Additionally, OFAC removed frequently asked questions 875, 876, and 877 from its website and made deletions to the Specially Designated Nationals and Blocked Persons list.

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

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