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  • 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

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  • OFAC updates Syrian sanctions guidance; issues DPRK advisory on information technology workers

    Financial Crimes

    On May 12, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) amended  a Frequently Asked Question (FAQ) and published a new General License (GL) regarding Syrian sanctions. Back in April (covered by InfoBytes here), OFAC published FAQ 884, which relates to non-U.S. persons’ (including nongovernmental organizations and foreign financial institutions) exposure to U.S. secondary sanctions under the Caesar Syrian Civilian Protection act of 2019 (Caesar Act). Specifically, FAQ 884 addresses sanctions exposure for activities authorized under the Syrian Sanctions Regulations. OFAC’s recent update of FAQ 884 clarifies that “OFAC will not consider transactions to be ‘significant’ for the purpose of a sanctions determination under the Caesar Act if U.S. persons would not require a specific license from OFAC to participate in such a transaction.” Additionally, GL 22 now authorizes “activities in certain economic sectors in non-regime held areas of Northeast and Northwest Syria.”

    Later in the week, OFAC announced that Treasury, the Department of State, and the FBI issued an advisory regarding an attempt by the Democratic People’s Republic of Korea (DPRK) and DPRK information technology (IT) workers to obtain employment while posing as non-DPRK nationals. Among other things, the advisory provides information on how DPRK IT workers operate and identifies red flags for companies to avoid hiring DPRK freelance developers. A Fact Sheet was also published to provide information on the advisory.

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

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  • OFAC sanctions ISIS facilitators

    Financial Crimes

    On May 9, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13224 against five Islamic State of Iraq and Syria (ISIS) financial facilitators operating across Indonesia, Syria, and Turkey for allegedly supporting financial transfers connected to ISIS efforts in Syria-based displaced persons camps by collecting funds in Indonesia and Turkey. As a result of the sanctions, all property and interests in property of the designated individuals within U.S. jurisdiction must be blocked and reported to OFAC. OFAC further noted that its regulations “generally prohibit” U.S. persons or persons within the United States from participating in transactions with the designated persons and warned foreign financial institutions that if they knowingly facilitate significant transactions for any of the designated individuals, OFAC may prohibit or impose strict conditions on the opening or maintaining of a U.S. correspondent account or payable-through account.

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

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  • OFAC sanctions ISIS facilitators

    Financial Crimes

    On March 1, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13224 against four Islamic State of Iraq and Syria (ISIS) and ISIS-Mozambique financial facilitators based in South Africa for allegedly supporting the transfer of funds from the top of the ISIS hierarchy to branches across Africa or for serving as leaders of ISIS cells. As a result of the sanctions, all property and interests in property of the designated individuals within U.S. jurisdiction must be blocked and reported to OFAC. OFAC further noted that its regulations “generally prohibit” U.S. persons or persons within the United States from participating in transactions with the designated persons and warned foreign financial institutions that if they knowingly facilitate significant transactions for any of the designated individuals, OFAC may prohibit or impose strict conditions on the opening or maintaining of a U.S. correspondent account or payable-through account.

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

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  • OFAC sanctions 15 international human rights abusers

    Financial Crimes

    On December 7, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13818 targeting fifteen actors across three countries under the Global Magnitsky Human Rights Accountability Act. According to OFAC, the sanctioned actors are associated with human rights abuse and repressive acts targeting civilians, political opponents, and peaceful protestors. As a result of the sanctions, all property and interests in property belonging to the sanctioned entities 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 noted that U.S. persons are prohibited from participating in transactions with these persons, which includes “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 OFAC Sanctions Of Interest to Non-US Persons Iran Syria Uganda OFAC Designations SDN List

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  • OFAC amends Syrian Sanctions Regulations

    Financial Crimes

    On November 24, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced an amendment to the Syrian Sanctions Regulations, 31 CFR part 542, which expands an existing authorization related to certain activities of nongovernmental organizations (NGOs) in Syria. The final rule permits NGOs to engage in additional transactions and activities in support of the not-for-profit activities. Additionally, OFAC published two new FAQs (see 937 and 938), which provide further information on Syrian sanctions. The final rule takes effect November 26.

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

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  • OFAC issues new Syria sanctions FAQ

    Financial Crimes

    On November 8, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) published new Syria FAQ 934, which relates to the United Nations and the U.S. government's stabilization and early recovery-related activities and transactions involving Syria. According to OFAC, the Syrian Sanctions Regulations (SySR) § 542.513 permit, under certain conditions, “the United Nations, its Specialized Agencies, Programmes, Funds, and Related Organizations and their employees, contractors, or grantees to engage in all transactions and activities in support of their official business in Syria, including any stabilization and early recovery-related activities and transactions in support of their official business.” This authorization applies to all United Nations employees, grantees, and contractors carrying out the official business of the United Nations, specialized agencies, programmes, funds, and related organizations. This includes nongovernmental organizations and private sector entities that act as grantees or contractors. 

    FAQ 934 also reiterates advice from FAQ 884 that non-U.S. persons, including nongovernmental organizations and foreign financial institutions “do not risk exposure to U.S. secondary sanctions pursuant to the Caesar Syria Civilian Protection Act of 2019” for activities that would be authorized for U.S. persons under the SySR. (Covered by InfoBytes here.)

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

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  • OFAC settles with Romanian bank for Iranian and Syrian sanctions violations

    Financial Crimes

    On August 27, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced a $862,318 settlement with a Romania-based bank and its U.S. parent company to resolve 98 apparent violations of OFAC’s Iran and Syria sanctions programs. According to OFAC’s web notice, the bank processed 98 commercial transactions totaling more than $3.5 million through U.S. banks on behalf of parties located in Iran and Syria. OFAC considered various aggravating factors in arriving at the settlement amount, including that the bank (i) demonstrated “a reckless disregard for U.S. sanctions regulations by failing to implement appropriate controls to comply with applicable U.S. regulations with respect to payments it processed” that had a “sanctions nexus that transited the U.S. financial system” or “after the bank became a foreign subsidiary of a U.S. person”; (ii) knew, or had reason to know, “it was processing payments on behalf of persons in Iran and Syria because of underlying finance and trade documents in its possession that referenced those countries”; and (iii) conveyed more than $3.5 million in economic benefit to Iranian and Syrian persons, thus causing harm to the integrity of U.S. sanctions programs and their associated policy objectives.

    OFAC also considered various mitigating factors, including that the bank voluntarily self-disclosed the apparent violations and the apparent violations constitute a non-egregious case. OFAC also determined that the bank (i) has not received a penalty notice from OFAC in the preceding five years; (ii) cooperated with OFAC’s investigation, conducted a lookback, and entered into a tolling agreement; and (iii) has undertaken remedial measures to ensure sanctions compliance. As such, OFAC noted that under its Economic Sanctions Enforcement Guidelines, the base civil money penalty amount is applicable in this matter with the final settlement amount reflecting OFAC’s consideration of general factors.

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

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  • OFAC sanctions Syrian officials and entities

    Financial Crimes

    On July 28, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Orders 13894 and 13572 against eight Syrian prisons run by the Assad regime’s intelligence apparatus, as well as five senior security officials of regime entities that control these detention facilities. A Syrian armed group and two of the group’s leaders were also sanctioned. “Today’s designations promote accountability for abuses committed against the Syrian people and deny rogue actors access to the international financial system,” OFAC Director Andrea M. Gacki stated. “This action demonstrates the United States’ strong commitment to targeting human rights abuses in Syria, regardless of the perpetrator.” As a result of the sanctions, all property and interests in property belonging to the sanctioned persons are blocked, and “any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked.” OFAC’s announcement further noted that OFAC regulations “generally prohibit” U.S. persons from participating in transactions with the designated persons unless exempt or otherwise authorized by a general or specific license.

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

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  • OFAC sanctions al-Qa’ida-linked financial facilitators

    Financial Crimes

    On July 28, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13224 against one Turkey-based al-Qa’ida financial facilitator for providing material assistance to al-Qa’ida and one Syria-based terrorist fundraiser and recruiter for providing material support to Hay’et Tahrir Al-Sham (HTS). According to OFAC, the designations “expose the continued efforts by al-Qa’ida and HTS to use the global formal financial system and highlight the need for continued vigilance against terrorist fundraising and recruitment on the internet.” 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,” that are subject to U.S. jurisdiction must be blocked and reported to OFAC. OFAC noted that OFAC regulations “generally prohibit” U.S. persons from participating in transactions with the designated persons unless exempt or otherwise authorized by a general or specific license. Furthermore, OFAC cautioned that “engaging in certain transactions with the individuals designated today entails risk of secondary sanctions,” and warned foreign financial institutions that if they knowingly facilitate significant transactions on behalf of a Specially Designated Global Terrorist, OFAC may prohibit or impose strict conditions on their opening or maintaining of correspondent accounts or payable-through accounts in the U.S.

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

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