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  • OFAC sanctions Nicaraguan persons

    Financial Crimes

    On June 17, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13851 against a state-owned Nicaraguan mining company and a high-ranking official for allegedly engaging in actions or policies that are used to “oppress the people of Nicaragua" and engaging "in activities that pose a threat to the security of the hemisphere.” According to OFAC, the company regulates gold mining through the issuance of land concessions to domestic and foreign companies, which feature several joint ventures with private firms. Furthermore, high-ranking members of the government regime have benefitted greatly from Nicaragua’s increase in gold exports, due in large part to the designated mining company. This oppressive regime has engaged in election rigging, OFAC said, and has deepened its relationship with Russia in its war against Ukraine, while using gold revenue to support its activities. As a result, all property and interests in property of the sanctioned individuals and entities, and any entities that own, directly or indirectly, 50 percent or more of such persons subject to U.S. jurisdiction, are blocked and must be reported to OFAC. U.S. persons are also generally prohibited from entering into transactions with the sanctioned persons.

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

  • OCC seeks comments on BSA/AML risk assessment

    On June 8, the OCC issued a notice in the Federal Register seeking comments concerning its information collection titled, ‘‘Bank Secrecy Act/Money Laundering Risk Assessment,’’ also known as the Money Laundering Risk (MLR) System. According to the notice, the MLR System “enhances the ability of examiners and bank management to identify and evaluate Bank Secrecy Act/Money Laundering and Office of Foreign Asset Control (OFAC) sanctions risks associated with banks’ products, services, customers, and locations.” The notice stated that the agency will collect MLR information for OCC supervised community and trust banks, and explained that the annual Risk Summary Form (RSF), which collects data about different products, services, customers, and geographies (PSCs), will include three significant changes in 2022. The changes in the 2022 RSF are: (i) the addition of six new PSCs; (ii) the addition of three new customer types under the money transmitters category; and (iii) the deletion of four existing PSCs. Comments close on August 8.

    Bank Regulatory Agency Rule-Making & Guidance Federal Issues OCC Federal Register Bank Secrecy Act Anti-Money Laundering OFAC Risk Management Financial Crimes Of Interest to Non-US Persons

  • OFAC sanctions members of Russian extremist group

    Financial Crimes

    On June 15, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13224, as amended, against two key supporters of a Russian extremist group. The U.S. State Department previously designated the extremist group as a Specially Designated Global Terrorist (SDGT) organization in 2020 for having provided training for acts of terrorism. Concurrent with OFAC’s action, the State Department is also designating an individual for posing a significant risk of committing acts of terrorism. According to Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson, the extremist group “has sought to raise and move funds using the international financial system with the intent of building a global network of violent groups that foster extremist views and subvert democratic processes.”

    As a result of the sanctions, all property and interests in property belonging to the sanctioned individuals in the U.S. are blocked and must be reported to OFAC. Additionally, “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.” OFAC noted that U.S. persons are prohibited from participating in transactions with the sanctioned persons unless authorized by an OFAC general or specific license or are otherwise exempt.

    OFAC further warned that engaging in certain transactions with the designated individuals entails risk of secondary sanctions, and cautioned that it can also “prohibit or impose strict conditions on the opening or maintaining in the United States of a correspondent account or a payable-through account of a foreign financial institution that either knowingly conducted or facilitated any significant transactions on behalf of a SDGT, or that, among other things, knowingly facilitates a significant transaction for [the extremist group] or certain persons designated for their connection to [the extremist group].”

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

  • OFAC issues Russia-related general licenses and FAQs

    Financial Crimes

    On June 14, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued Russia-related General License (GL) 8C, which authorizes (with certain enumerated exceptions) transactions related to energy. According to the GL, all transactions prohibited by Executive Order (E.O.) 14024 involving entities that are related to energy are authorized, through December 5, 2022, under certain circumstances. OFAC also published amended FAQs, which provide further information on GL 8C, and clarify Russian sanction information under E.O. 14024, among other things.

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

  • OFAC clarifies certain Russia-related prohibitions

    Financial Crimes

    On June 9, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced the publication of new Russia-related FAQs. Among other things, the FAQs provide information on the previously issued Determination Pursuant To Section 1(a)(ii) of E.O. 14071, which prohibits “the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of accounting, trust and corporate formation, or management consulting services to any person located in the Russian Federation” unless licensed or otherwise authorized by OFAC (covered by InfoBytes here). Specifically, FAQ 1063 explains that “[t]he prohibitions imposed by the determination do not distinguish between new and existing trusts and companies.” Additionally, FAQ 1067 provides that “[t]he determination does not prohibit U.S. persons from exporting, reexporting, selling, or supplying, directly or indirectly, software to the Russian Federation.”

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

  • OFAC issues Covid-related general licenses and FAQs

    Financial Crimes

    On June 10, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued Syria General License (GL) 21AVenezuela GL 39A, and Iran GL N-1, “Authorizing Certain Activities to Respond to the Coronavirus Disease 2019 (COVID-19) Pandemic.” Each GL authorizes certain Covid-19-related transactions through June 17, 2023. Additionally, OFAC updated Frequently Asked Questions regarding the purposes of the GLs and provided clarifying information.

    Financial Crimes Of Interest to Non-US Persons OFAC Covid-19 Iran Venezuela Syria OFAC Sanctions OFAC Designations

  • OFAC amends Cuban Assets Control Regulations

    Financial Crimes

    On June 8, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced a final rule amending the Cuban Assets Control Regulations, and further implementing portions of President Biden’s foreign policy to increase support for Cuban people. Specifically, the final rule “authorizes group people-to-people educational travel to Cuba and removes certain restrictions on authorized academic educational activities, authorizes travel to attend or organize professional meetings or conferences in Cuba, removes the $1,000 quarterly limit on family remittances, and authorizes donative remittances to Cuba.” The final rule is effective June 9.

    In conjunction with the announcement, OFAC published a number of new and updated Cuba-related frequently asked questions addressing, among other things, remittance transactions, travel activities, and authorized imports.

    Financial Crimes Agency Rule-Making & Guidance Department of Treasury OFAC Of Interest to Non-US Persons OFAC Sanctions OFAC Designations Cuba

  • OFAC sanctions actors throughout the Western Balkans

    Financial Crimes

    On June 6, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions against two prominent officials in Bosnia and Herzegovina. This is the third action taken under E.O. 14033. According to the Under Secretary of the Treasury for Terrorism and Financial Intelligence, the designated individuals “have each sought to pursue ethnonationalist and political agendas at the expense of the democratic institutions and citizens of Bosnia and Herzegovina.” As a result of the sanctions, all assets belonging to the designated 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 dealings involving any property or interests in property of the blocked or designated persons.

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

  • Terrorist Financing Targeting Center members designate financial facilitators of terrorism

    Financial Crimes

    On June 6, the U.S. Treasury Department announced that member nations of the Terrorist Financing Targeting Center (TFTC) have jointly designated 16 individuals, entities, and groups affiliated with a variety of regional terrorist organizations. This marks the fifth year of coordinated TFTC sanctions actions targeting terrorist financing, Treasury stated. The sanctioned persons, who were all previously designated by the U.S., include three individuals associated with Iran’s Islamic Revolutionary Guard Corps-Qods Force, four ISIS-associated individuals and one company, six Boko Haram financiers, and two terrorist groups. The TFTC was created to counter regional money laundering and terrorist financing networks by “identifying, tracking, and sharing information about terrorist financing networks; coordinating joint disruptive actions; and offering capacity-building training and assistance in countering the financing of terrorism,” and serves to enhance multilateral efforts among the U.S. and the Gulf countries of Bahrain, Kuwait, Oman, Qatar, Saudi Arabia, and the United Arab Emirates.

    Financial Crimes Of Interest to Non-US Persons Department of Treasury OFAC OFAC Sanctions OFAC Designations Combating the Financing of Terrorism Anti-Money Laundering Terrorist Financing Targeting Center

  • OFAC sanctions individuals connected to Mexican cartels

    Financial Crimes

    On June 2, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 14059 against six individuals for engaging with a Mexico-based drug traffic organization. Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson stated that “[v]iolence and corruption have been critical to [the organization’s] growth in the past decade,” which has “fueled the cartel’s territorial expansion, and with it a greater capacity to traffic deadly drugs to the United States.” The sanctions are the result of a collaboration between Treasury, the Government of Mexico, and the U.S. Drug Enforcement Administration (DEA) with support from the U.S. Customs and Border Protection. As a result of the sanctions, the designated persons’ 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 persons.

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

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