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  • OFAC sanctions Houthi military official

    Financial Crimes

    On May 21, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13611 against a key senior military official connected to the Ansarallah, sometimes referred to as the Houthis, for allegedly arranging attacks impacting Yemeni civilians. According to OFAC, the sanctioned individual recently led the offense against Yemeni government-held territory in the Marib province, which “puts approximately one million already vulnerable internally displaced people (IDP) at risk, threatens to overwhelm an already stretched humanitarian response, and is triggering broader escalation.” As a result of the sanctions, all property and interests in property belonging to the sanctioned individual, and “any entities that are owned, directly or indirectly, 50 percent or more” by the individual that are subject to U.S. jurisdiction are blocked and must be reported to OFAC. OFAC’s announcement further noted that OFAC regulations “generally prohibit” U.S. persons from participating in transactions with designated persons unless exempt or otherwise authorized by a general or specific license, and warned foreign financial institutions that if they knowingly facilitate significant transactions for any of the designated persons, they may be subject to U.S. correspondent account or payable-through account sanctions.

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

  • OFAC authorizes certain PEESA transactions and activities

    Financial Crimes

    On May 21, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued Protecting Europe’s Energy Security Act of 2019 (PEESA) General License (GL) 1, which authorizes certain activities otherwise prohibited involving the Federal State Budgetary Institution Marine Rescue Service (MRS). However, GL 1 does not authorize any transactions or activities involving any vessels identified on OFAC’s Non-SDN Menu-Based Sanctions List “as blocked property of MRS or of any entity in which MRS owns, directly or indirectly, a 50 percent or greater interest,” or any PEESA prohibited transactions or activities. OFAC also issued related FAQs 894 and 895 and added entities and vessels to its Non-SDN Menu-Based Sanctions List. Furthermore, OFAC added two vessels to the Specially Designated National List, and reiterated in FAQ 895 that “property and interests in property of persons on the SDN List are blocked and any entity owned 50 percent or more, individually or in the aggregate, directly or indirectly, by one or more blocked persons is itself blocked.”

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

  • OFAC amends Terrorism List Governments Sanctions Regulations

    Financial Crimes

    On May 19, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued a final rule to amend the Terrorism List Governments Sanctions Regulations to implement changes resulting from the Secretary of State’s December 14, 2020 rescission of the designation of Sudan as a State Sponsor of Terrorism. The amendments relate to “removing one general license in full and amending another general license to remove references to the Government of Sudan and Sudanese nationals because financial transactions with the Government of Sudan are no longer prohibited by the Terrorism List Governments Sanctions Regulations.” The rule went into effect on May 20 immediately upon publication in the Federal Register.

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

  • OFAC amends security investment-related general license

    Financial Crimes

    On May 18, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued General License (GL) 1B, “Authorizing Transactions Involving Securities of Certain Communist Chinese Military Companies.” GL 1B authorizes through June 11 (9:30 a.m. eastern daylight time) certain transactions and activities that involve “publicly traded securities, or any securities that are derivative of, or are designed to provide investment exposure to such securities, of an entity whose name closely matches, but does not exactly match, the name of a Communist Chinese military company as defined by section 4(a) of E.O. 13959.” However, GL 1B does not authorize “[a]ny transactions or activities involving publicly traded securities, or any securities that are derivative of, or are designed to provide investment exposure to such securities of entities identified in the Office of Foreign Assets Control’s Non-SDN Communist Chinese Military Companies List (NS-CCMC List) pursuant to section 4(a)(iii) of E.O. 13959, as amended, as a subsidiary of a person determined to be a Communist Chinese military company, including entities added to the NS-CCMC List on January 8, 2021.” GL 1B immediately replaces and supersedes GL 1A, dated January 26.

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

  • OFAC sanctions ISIS financial facilitators in Syria and Turkey

    Financial Crimes

    On May 17, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13224 against three individuals and one entity connected to the Islamic State of Iraq and Syria (ISIS) for allegedly helping ISIS access the financial system in the Middle East through a network of international donors. OFAC noted that these sanctions coincide with the fourteenth meeting of the Counter ISIS Finance Group, which coordinates efforts to isolate ISIS from the international financial system and eliminate revenue sources. As a result of the sanctions, all property and interests in property belonging to the sanctioned persons, and “any entities that are owned, directly or indirectly, 50 percent or more” by them that are subject to U.S. jurisdiction are blocked and must be reported to OFAC. 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, and warned foreign financial institutions that if they knowingly facilitate significant transactions for any of the designated persons, they may be subject to U.S. correspondent account or payable-through account sanctions.

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

  • OFAC sanctions Burmese governing body and numerous individuals

    Financial Crimes

    On May 17, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 14014 against 16 individuals connected to Burma’s military regime and one entity, the State Administration Council (SAC), which is the official name of the military government in Burma formed by Burma’s military on February 2, 2021. As a result of the sanctions, all property and interests in property belonging to the SAC and the identified individuals subject to U.S. jurisdiction are blocked and must be reported to OFAC. According to Andrea Gacki, Director of OFAC, these sanctions “promote accountability for those responsible for the coup and ongoing violence.” Additionally, “any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked.” The sanctions also generally prohibit U.S. persons from engaging in any dealings involving the property or interests in property of the SAC or the identified individuals.

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

  • OFAC amends narcotics trafficking and kingpin-related sanctions regulations

    Financial Crimes

    On May 14, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued a final rule to amend the Narcotics Trafficking Sanctions Regulations (NTSR) and Foreign Narcotics Kingpin Sanctions Regulations (FNKSR). The amendments relate to “general licenses for payments for legal services, certain transactions for personal maintenance, certain transactions for maintenance of blocked tangible property, and emergency medical services.” In addition, the final rule updates regulatory provisions prohibiting transactions involving blocked property and clarifies the terms “evasions,” “attempts,” and “conspiracies” in the NTSR and the FNKSR so that they are consistent with the definitions of those terms in other OFAC sanctions regulations.

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

  • Broker-dealer settles with SEC for failing to file SARs

    Securities

    On May 12, the SEC announced a settlement with a broker-dealer for allegedly violating the Securities and Exchange Act by failing to consistently implement its anti-money laundering (AML) program and file Suspicious Activity Reports (SARs) despite knowing individuals were attempting to gain unauthorized access to retirement accounts. According to the SEC’s order, from September 2015 through October 2018, the broker-dealer allegedly knew that individuals were attempting to gain access, or had gained access, to plan participants’ retirement accounts through the use of improperly obtained personal identifying information. The SEC alleged that, despite this knowledge, the broker-dealer failed to file approximately 130 SARs in cases where it had detected the suspicious activity and, in the roughly 297 SARs that it did file, failed to include certain required information linked to the bad actors, such as URL addresses, IP addresses, and other electronic identifying information. The order requires the broker-dealer, who has neither admitted nor denied the SEC’s allegations, to cease and desist from future violations and pay a $1.5 million penalty. The SEC acknowledged the broker-dealer’s significant cooperation in the investigation and subsequent remedial efforts.

    Securities Enforcement SARs Financial Crimes Anti-Money Laundering Securities Exchange Act

  • OFAC sanctions Mexican cartel members and facilitator

    Financial Crimes

    On May 12, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to the Foreign Narcotics Kingpin Designation Act against a commander and his organization responsible for facilitating drug trafficking between Mexico and the U.S. OFAC also designated six other individuals and one entity as Specially Designated Narcotics Traffickers pursuant to the Kingpin Act for their connections to the organization. Director of OFAC Andrea Gacki noted that the sanctioned organization “help[s] fuel our nation’s opioid epidemic” and that “Treasury and our U.S. government partners, including the Drug Enforcement Administration, will continue to use every available resource to dismantle these criminal networks.” As a result of the sanctions, all property belonging to the sanctioned persons 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 of blocked or designated persons.

    These sanctions against the drug trafficking cartel are the most recent efforts taken by OFAC pursuant to the Kingpin Act (covered in InfoBytes, here and here).

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

  • OFAC sanctions Mexican cartel members and facilitator

    Financial Crimes

    On May 12, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to the Foreign Narcotics Kingpin Designation Act against a commander and his organization responsible for facilitating drug trafficking between Mexico and the U.S. OFAC also designated six other individuals and one entity as Specially Designated Narcotics Traffickers pursuant to the Kingpin Act for their connections to the organization. Director of OFAC Andrea Gacki noted that the sanctioned organization “help[s] fuel our nation’s opioid epidemic” and that “Treasury and our U.S. government partners, including the Drug Enforcement Administration, will continue to use every available resource to dismantle these criminal networks.” As a result of the sanctions, all property belonging to the sanctioned persons 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 of blocked or designated persons.

    These sanctions against the drug trafficking cartel are the most recent efforts taken by OFAC pursuant to the Kingpin Act (covered in InfoBytes, here and here).

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

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