Skip to main content
Menu Icon Menu Icon
Close

InfoBytes Blog

Financial Services Law Insights and Observations

Filter

Subscribe to our InfoBytes Blog weekly newsletter and other publications for news affecting the financial services industry.

  • OFAC sanctions Iranian media corporation

    Financial Crimes

    On November 16, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13846 against six senior employees of the Iranian state-run media corporation that has broadcast hundreds of forced confessions of Iranian, dual national, and international detainees in Iran. According to OFAC, the corporation was designated in 2013 and does not act “as objective media outlet but rather as a critical tool in the Iranian government’s mass suppression and censorship campaign against its own people.” OFAC also noted that the corporation has “recently broadcast televised interviews of individuals being forced to confess that their relatives were not killed by Iranian authorities during nationwide protests but died due to accidental, unrelated causes.” 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 designation. 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 Department of Treasury OFAC OFAC Sanctions OFAC Designations Iran SDN List

    Share page with AddThis
  • OFAC sanctions firms for aiding Russia’s acquisition of UAVs

    Financial Crimes

    On November 15, the U.S. Treasury Department’s Office of Foreign Assets Control announced sanctions pursuant to Executive Orders (E.O.) 13382 and 14024 against several firms responsible for the production and transfer of Iranian unmanned aerial vehicles (UAVs) to Russia for use in the country’s war against Ukraine. OFAC also designated two individuals who facilitated the acquisition of UAVs for a previously State Department-designated company. According to the announcement, the designations “implement commitments to target international actors involved in supporting Russia’s war machine, as highlighted by OFAC FAQs 1091 and 1092 and reinforced by an October 14, 2022 meeting of senior officials in Washington representing ministries of finance and other government agencies from 33 countries, in which the participants acknowledged the significance of sanction actions taken so far and discussed additional steps to further impair Russia’s military-industrial complex and critical defense supply chains.” The sanctions follow OFAC’s September designations against several persons involved in the shipment, production, and procurement of UAVs for Russia’s benefit. (Covered by InfoBytes here.) As a result of the sanctions, all property and interests in property belonging to the sanctioned individuals and entities subject to U.S. jurisdiction are blocked and must be reported to OFAC. U.S. persons are also generally prohibited from engaging in any dealings involving the property or interests in property of blocked or designated persons. Additionally, persons that engage in certain transactions with the sanctions individuals or entities may themselves be exposed to sanctions. OFAC further warned that “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.”

    The same day, the Departments of Treasury, Commerce, and State issued a joint alert detailing the impact of international sanctions and export controls on Russia’s military-industrial complex to date.

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

    Share page with AddThis
  • OFAC issues new counter terrorism GL and FAQ

    Financial Crimes

    On November 15, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued Counter Terrorism General License (GL) 21, “Authorizing Limited Safety and Environmental Transactions Involving Certain Vessels,” which authorizes limited safety and environmental transactions involving certain persons or vessels that are normally prohibited by the Global Terrorism Sanctions Regulations (GTSR) through 12:01 a.m. EST, December 15, 2022. OFAC explained that such transactions are authorized provided payments to a blocked person are made into a blocked account in accordance with the GTSR. A list of unauthorized transactions are also included. OFAC also issued related FAQ 1097 to provide additional clarification on permitted transactions.

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

    Share page with AddThis
  • OFAC issues GL and FAQ regarding Russian transactions

    Financial Crimes

    On November 10, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced the issuance of Russia-related General License (GL) 53 and related FAQ. GL 53 authorizes transactions for diplomatic missions of the Russian Federation prohibited by Directive 4 under Executive Order 14024, under certain circumstances. FAQ 1096 clarifies GL 53, noting that the authorizations in GL 53 apply to transactions related to Russian missions located in or outside the U.S. The FAQ also explains that “GL 53 does not authorize any transactions involving blocked persons, including blocked Russian financial institutions; nor does it authorize debits to the accounts on the books of U.S. financial institutions of entities subject to Directive 4.”

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

    Share page with AddThis
  • OFAC sanctions individuals and networks supporting Russia’s invasion

    Financial Crimes

    On November 14, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order (E.O.) 14024 against a total of 14 individuals and 28 entities, including a transnational network that procures technology in support of Russia’s military-industrial complex, and “a global network of financial facilitators, enablers, and others associated with two key Kremlin-linked elites whose fortunes are intertwined with the West.” OFAC also identified eight aircrafts as blocked property. “The United States will continue to expose and disrupt the Kremlin’s military supply chains and deny Russia the equipment and technology it needs to wage its illegal war against Ukraine,” Treasury Secretary Janet L. Yellen said in the announcement. “Together with our broad coalition of partners, we will continue to use our sanctions and export controls to weaken Russia’s military on the battlefield and cut into the revenue Putin is using to fund his brutal invasion.” 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 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 OFAC license.

    In conjunction with the sanctions, OFAC issued Russia-related General License (GL) 40C related to civil aviation safety. GL 40C authorizes certain transactions normally prohibited by E.O. 14024 that are “ordinarily incident and necessary to the provision, exportation, or reexportation of goods, technology, or services to ensure the safety of civil aviation involving one or more of the blocked entities” provided the “aircraft is registered in a jurisdiction solely outside of the Russian Federation.”

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

    Share page with AddThis
  • OFAC announces sanctions tied to drug trafficking

    Financial Crimes

    On November 9, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 14059 against three individuals and nine entities for supplying certain drugs to U.S. markets through internet sales and a host of shell companies. OFAC noted that the sanctions would not have been possible without collaboration with the Drug Enforcement Administration and Homeland Security Investigations. 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 designated individuals or entities may themselves be exposed to sanctions or enforcement action, OFAC warned.

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

    Share page with AddThis
  • OFAC sanctions individuals associated with al-Qa’ida

    Financial Crimes

    On November 9, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13224 against two business associates of a previously sanctioned al-Qa’ida financial facilitator and external operations plotter. According to OFAC, the two designated individuals in the recent action conducted business activities to assist the previously designated individual for facilitating the international movement of individuals and finances in furtherance of al-Qa’ida’s objectives. 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 designated individuals or entities may themselves be exposed to secondary sanctions, OFAC warned, adding that foreign financial institutions that knowingly conduct or facilitate significant transactions to any of the sanctioned persons could also be subject to U.S. sanctions.

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

    Share page with AddThis
  • OFAC updates FAQs related to sanctioned virtual currency “mixer”

    Financial Crimes

    On November 8, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) published one new and three amended cyber-related FAQs related to sanctions issued in August against a virtual currency mixer accused of allegedly laundering more than $7 billion. As previously covered by InfoBytes, OFAC claimed the company “repeatedly failed to impose effective controls designed to stop it from laundering funds for malicious cyber actors on a regular basis.” Newly added FAQ 1095 clarifies that a designated “person” under Executive Order 13722 or 13694 is a “partnership, association, joint venture, corporation, group, subgroup, or other organization.” Amended FAQs 1076, 1078, and 1079 (i) explain how persons can complete transactions or withdraw virtual currency without violating U.S. sanctions regulations; (ii) clarify whether OFAC reporting obligations apply to “dusting” transactions (wherein “certain U.S. persons may have received unsolicited and nominal amounts of virtual currency or other virtual assets from [the sanctioned company’s] smart contracts”; and (iii) outline prohibitions resulting from the sanctions.

    Financial Crimes Of Interest to Non-US Persons OFAC Department of Treasury OFAC Sanctions OFAC Designations Anti-Money Laundering Digital Assets Virtual Currency

    Share page with AddThis
  • OFAC sanctions individuals connected to DPRK

    Financial Crimes

    On November 8, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions against two individuals for engaging in activities related to transportation and procurement activities on behalf of the Democratic People’s Republic of Korea (DPRK). According to OFAC, these individuals acted on behalf of an entity previously designated by OFAC for operating in the transportation industry in the DPRK economy (covered by InfoBytes here). OFAC also noted that the designation is a part of continuing efforts by the U.S. to limit DPRK’s ability to advance its unlawful weapons of mass destruction and ballistic missile programs, and follows numerous recent DPRK ballistic missile launches. As a result, all property, and interests in property of the designated persons that are in the U.S. or in the possession or control of U.S. persons, must be blocked and reported to OFAC. OFAC regulations generally prohibit all dealings by U.S. persons or within the U.S. (including transactions transiting the U.S.) that involve any property or interests in property of blocked or designated persons. OFAC further warned that engaging in certain transactions with the designated individuals and entities entails risk of designation. Additionally, OFAC warned that a foreign financial institution that knowingly facilitates a significant transaction or provides significant financial services for any of the designated individuals or entities could be subject to U.S. correspondent or payable-through account sanctions.

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

    Share page with AddThis
  • OFAC announces sanctions involving Burma’s military regime

    Financial Crimes

    On November 8, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 14014 against an individual and an entity that facilitate weapons purchases for Burma’s military regime. According to OFAC, the designation is in conjunction with newly issued European Union sanctions. OFAC also noted that “Burma’s military regime has continued to oppress and deny the will of the people to chart an inclusive, democratic future for their country,” and that the sanctions are not targeted toward the people of Burma but at “those who profit from the oppressive actions of the regime by operating in the defense sectors of Burma’s economy and by enabling Burma’s military connections to foreign militaries.” As a result of the sanctions, all property and interests in property belonging to the sanctioned persons that are in the United States or in the possession or control of U.S. persons 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 generally prohibited from engaging in any dealings involving the property or interests in property of blocked or designated persons, unless authorized by a general or specific OFAC license, or if otherwise exempt.

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

    Share page with AddThis

Pages