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  • OFAC sanctions Iranian officials for serious human rights abuses

    Financial Crimes

    On March 8, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions, pursuant to Executive Orders 13553 and 13846, against several Iranian regime officials and entities for serious human rights abuses against women and girls. Included among the sanctioned individuals are “the top commander of the Iranian army and a high-ranking leader in the Islamic Revolutionary Guard Corps (IRGC), as well as an Iranian official who was central to the regime’s efforts to block internet access.” OFAC also imposed sanctions against three Iranian companies and their leadership for their role in enabling the violent repression by the Iranian Law Enforcement Forces of peaceful protestors. The actions, taken in coordination with the EU, UK, and Australia, mark the continued effort to impose sanctions on persons who engage in serious human rights abuse or censorship with respect to Iran.

    As a result of the sanctions, all property and interests in property belonging to the sanctioned persons subject to U.S. jurisdiction are blocked and must be reported to OFAC. Additionally, “any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked.” OFAC further warned that “persons that engage in certain transactions with the persons designated today may themselves be exposed to sanctions or subject to an enforcement action,” and that “any foreign financial institution that knowingly facilitates a significant transaction or provides significant financial services for any of the persons designated today could be subject to U.S. sanctions.”

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

  • OFAC sanctions 9 companies for involvement in Iranian petrochemicals and petroleum

    Financial Crimes

    On February 9, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions, pursuant to Executive Order 13846, against six Iran-based petrochemical manufacturers or their subsidiaries, as well as three firms located in Malaysia and Singapore, for their involvement in the sale and shipment of petroleum and petrochemicals on behalf of a previously designated company. According to the announcement, the designations follow sanctions imposed by OFAC last November against 13 companies in multiple jurisdictions for their involvement in the sale of Iranian petrochemicals and petroleum products to buyers in East Asia on behalf of sanctioned Iranian petrochemical brokers (covered by InfoBytes here). As a result of the sanctions, all property and interests in property belonging to the sanctioned persons subject to U.S. jurisdiction are blocked and must be reported to OFAC. Additionally, “any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked.” U.S. persons are also generally prohibited from engaging in any dealings involving the property or interests in property of blocked or designated persons. Persons that engage in certain transactions with the individuals or entities designated today may themselves be exposed to sanctions or subject to enforcement. Additionally, OFAC warned that “any foreign financial institution that knowingly facilitates a significant transaction or provides significant financial services for any of the individuals designated today could be subject to U.S. sanctions.”

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

  • OFAC sanctions senior executives of Iranian UAV manufacturer

    Financial Crimes

    On February 3, the U.S. Treasury Department’s Office of Foreign Assets Control announced sanctions pursuant to Executive Order 13382 against eight senior executives of an Iran-based firm that was previously sanctioned by the U.S. and EU for manufacturing unmanned aerial vehicles (UAVs) for Iran’s Islamic Revolutionary Guard Corps (IRGC) Aerospace Force. OFAC also designated two Islamic Republic of Iran Navy vessels as property in which the Government of Iran has an interest. “Iranian entities continue to produce UAVs for Iran’s IRGC and military. More broadly, Iran is supplying UAVs for Russia’s combat operations to target critical infrastructure in Ukraine,” Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson said in the announcement. “The United States will continue to aggressively target all elements of Iran’s UAV program.”

    As a result of the sanctions, all property and interests in property belonging to the sanctioned persons that are in the U.S. or in the possession or control of U.S. persons are blocked and must be reported to OFAC. Further, “any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked.” U.S. persons are generally prohibited from engaging in any dealings involving the property or interests in property of blocked or designated persons. Persons that engage in certain transactions with the designated individuals or entities may themselves be exposed to sanctions, and “any foreign financial institution that knowingly facilitates a significant transaction or provides significant financial services for any of the individuals or entities designated today pursuant to E.O. 13382 could be subject to U.S. sanctions.”

    Financial Crimes Of Interest to Non-US Persons OFAC OFAC Designations OFAC Sanctions SDN List Iran Russia Ukraine Invasion

  • OFAC sanctions IRGC foundation and Iranian senior officials

    Financial Crimes

    On January 23, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13553 against Iran’s Islamic Revolutionary Guard Corps (IRGC) Cooperative Foundation, five of the foundation’s board members, the Deputy Minister of Intelligence and Security, and four senior IRGC commanders in Iran. According to OFAC, the sanctions—imposed in coordination with the UK and EU—target a key economic pillar of the IRGC.

    OFAC stressed that this “is the ninth round of OFAC designations targeting actors responsible for the crackdown on peaceful demonstrators and efforts to disrupt and cut Iran’s access to the global internet since nationwide protests began in 2022.” As a result of the sanctions, all property and interests in property belonging to the sanctioned persons that are in the U.S. or in the possession or control of U.S. persons are blocked and must be reported to OFAC. Further, “any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked.” U.S. persons are generally prohibited from engaging in any dealings involving the property or interests in property of blocked or designated persons. Persons that engage in certain transactions with the designated persons may themselves be exposed to sanctions, and “any foreign financial institution that knowingly facilitates a significant transaction or provides significant financial services for any of the persons designated today could be subject to U.S. sanctions.”

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

  • OFAC issues and amends Iran-related FAQ

    Financial Crimes

    On January 11, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) published an Iran-related frequently asked question (FAQ) and amended several other Iran-related FAQs. New FAQ 1110 clarifies Iran General License (GL) D-1 and GL D-2. Specifically, OFAC noted that because GL D-1 was issued in 2014, the types of software and services that support communication over the internet have changed. Therefore, to reflect technological developments in communication-related software and services since the issuance of GL D-1 (including in cloud-based services), OFAC issued GL D-2 to expand and clarify the range of U.S. software and services available to Iranians under OFAC’s sanctions program.

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

  • OFAC sanctions suppliers of Iranian UAVs used in Russia’s war against Ukraine

    Financial Crimes

    On January 6, the U.S. Treasury Department’s Office of Foreign Assets Control announced sanctions pursuant to Executive Order 13382 against six executives and board members of a U.S.-designated Iranian defense manufacturer allegedly responsible for designing and producing unmanned aerial vehicles (UAVs) that are being transferred by Iran for use in Russia’s war against Ukraine. The director of a key organization responsible for overseeing Iran’s ballistic missile programs has also been sanctioned. OFAC further announced that it is updating the defense manufacturer’s entry on the Specially Designated Nationals and Blocked Persons List to include its new alias. As a result of the sanctions, all property and interests in property belonging to the sanctioned individuals and entities that are in the U.S. or in the possession or control of U.S. persons are blocked and must be reported to OFAC. Further, “any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked.” U.S. persons are generally prohibited from engaging in any dealings involving the property or interests in property of blocked or designated persons. Persons that engage in certain transactions with the designated individuals or entities may themselves be exposed to sanctions, and “any foreign financial institution that knowingly facilitates a significant transaction or provides significant financial services for any of the individuals or entities designated today pursuant to E.O. 13382 could be subject to U.S. sanctions.”

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

  • OFAC settles with Danish company for routing prohibited financial transactions though a U.S. bank

    Financial Crimes

    On December 30, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced a more than $4.3 million settlement with a multinational Danish manufacturer to resolve allegations that its wholly owned United Arab Emirates (UAE)-based subsidiary directed customers in Iran, Syria, and Sudan to make payments to its bank account at the UAE branch of a U.S. financial institution. According to OFAC’s enforcement release, between November 2013 and August 2017, the subsidiary sold products to customers in Sudan, Syria, and Iran. Customers were instructed to remit payments to at least three accounts at banks located in the UAE, including the parent company’s U.S. branch account. OFAC further contended that the subsidiary used third-party payers to make five transfers (disguising the originator or beneficiary of the transactions) from its U.S. branch account to parties in Syria and Iran, which prevented the bank’s transactional screen filters from stopping the payments. The total value of all the transfers was roughly $16,959,683, OFAC said, claiming that by causing a U.S. financial institution to facilitate prohibited financial transactions and export financial services, the parent company violated the Iranian, Syrian, and Sudanese sanctions regulations.

    While OFAC found no evidence that the parent company willfully engaged third-party payers to evade sanctions, it determined that the subsidiary “was aware since at least 2011 that using a U.S. financial institution to send or receive payments related to sanctioned jurisdictions could be prohibited.” Moreover, the subsidiary allegedly received communications from the parent company and various financial institutions regarding concerns flagged in its banking activity but continued to use the U.S. branch account to collect payments from customers in sanctioned jurisdictions. These alleged violations, OFAC stated, occurred primarily due to deficiencies in the parent company’s global sanctions compliance program.

    OFAC noted that while the parent company disclosed the alleged violations, the agency was already in possession of the relevant information and therefore the submission did not qualify as a voluntary self-disclosure. However, OFAC considered various mitigating factors, including that the parent company had not received a penalty notice from OFAC in the preceding five years, and the parent company took quick action to determine the root causes of the alleged conduct and undertook significant remedial measures to prevent future violations.

    Providing context for the settlement, OFAC stated that the “enforcement action highlights the risks to multinational companies, including to non-U.S. entities, that involve the U.S. financial system in commercial activity involving an OFAC- sanctioned country, region, or person,” and emphasized that “[c]ommercial activity that might not otherwise violate OFAC regulations—such as the sale of non-U.S. goods by a non-U.S. person to an entity in an OFAC-sanctioned country—can nonetheless cause a violation when the financial transactions related to that activity are processed through or involve U.S. financial institutions.”

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

  • OFAC sanctions Iranian officials

    Financial Crimes

    On December 21, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13553 against the prosecutor general and key military and paramilitary officials in Iran, as well as a company manufacturing and providing Iran’s Law Enforcement Forces with anti-riot equipment. According to OFAC, the designations target the senior official overseeing the prosecution of protestors, as well as leaders of military and paramilitary organizations accused of violently cracking down and detaining protestors, and a company that procures and provides security forces with tools of suppression. As a result of the sanctions, all property and interests in property belonging to the sanctioned persons subject to U.S. jurisdiction are blocked and must be reported to OFAC. Additionally, “any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked.” U.S. persons are also generally prohibited from engaging in any dealings involving the property or interests in property of blocked or designated persons. Persons that engage in certain transactions with the individuals designated today may themselves be exposed to designation. Additionally, OFAC warned that “any foreign financial institution that knowingly facilitates a significant transaction or provides significant financial services for any of the persons designated today could be subject to U.S. sanctions.”

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

  • OFAC designates sanctions evasion network connected to IRGC-QF

    Financial Crimes

    On December 8, the U.S. Treasury Department’s Office of Foreign Assets Control announced sanctions pursuant to Executive Order 13224 against a sanctions evasion network for facilitating and concealing the sale and shipment of hundreds of millions of dollars’ worth of oil for Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF). According to OFAC, the designated individual’s companies “established international sales contracts for Iranian oil with foreign purchasers, arranged shipments of oil, and helped launder the proceeds, obscuring the oil’s Iranian origin and the IRGC-QF’s interest in the sales.” The action supplements designations announced in May, which targeted an element of this network responsible for facilitating millions of dollars’ worth of Iranian oil sales for both the IRGC-QF and Hizballah, backed by senior levels of the Russian Federation government and state-run entities (covered by InfoBytes here). As a result, all property, and interests in property of the designated individuals and entities, “and of 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 transactions with the designated persons unless authorized by a general or specific OFAC license or are otherwise exempt. OFAC further warned that “engaging in certain transactions with the individuals and entities designated today entails risk of secondary sanctions.”

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

  • OFAC sanctions Iranian officials

    Financial Crimes

    On November 23, the U.S. Treasury Department Office of Foreign Assets Control (OFAC)) announced sanctions pursuant to Executive Order 13553 against three Iranian security officials related to the Iranian regime’s continued crackdown on ongoing protests throughout the country, including most recently in Kurdish areas. According to OFAC, the Iranian regime has increased its aggressive actions against the Iranian people as part of its ongoing suppression of peaceful protests against a regime that denies human rights and fundamental freedoms to its people. As a result of the sanctions, all property and interests in property belonging to the sanctioned persons subject to U.S. jurisdiction are blocked and must be reported to OFAC. Additionally, “any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked.” U.S. persons are also generally prohibited from engaging in any dealings involving the property or interests in property of blocked or designated persons. Persons that engage in certain transactions with the individuals designated today may themselves be exposed to designation. Additionally, OFAC warned that “any foreign financial institution that knowingly facilitates a significant transaction or provides significant financial services for any of the persons designated today could be subject to U.S. sanctions.”

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

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