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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 announces first-ever sanctions against virtual currency mixer

    Financial Crimes

    On May 6, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13722 against a virtual currency mixer used by the Democratic People’s Republic of Korea (DPRK) to support its cyber activities and money-laundering. According to OFAC, in March, a DPRK state-sponsored cyber-hacking group carried out the largest virtual currency heist to date, worth almost $620 million, from a blockchain project linked to an online game. The virtual currency mixer was used to process over $20.5 million of the illicit proceeds. OFAC noted that the sanctions are the first-ever sanctions on a virtual currency mixer. 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.” U.S. persons are generally prohibited from engaging in any dealings involving the property or interests in property of blocked or designated persons.

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

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  • OFAC sanctions facilitators of Russian sanctions evasion

    Financial Crimes

    On April 20, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 14024 against several entities and numerous individuals for attempting to evade sanctions imposed by the U.S. and its international partners on Russia. Included in the designations are a Russian commercial bank, a global network comprised of more than 40 individuals and entities led by a previously designated Russian oligarch (“including organizations whose primary mission is to facilitate sanctions evasion for Russian entities”), and several companies operating in Russia’s virtual currency mining industry. According to OFAC, this is the first time a virtual currency mining company has been sanctioned. In coordination with OFAC’s sanctions, the Department of State took further action by imposing visa restrictions on 635 Russian nationals and three Russian Federation officials for their involvement in human rights abuses, as well as 17 individuals responsible for undermining democracy in Belarus.

    As a result of the sanctions, all property and interests in property belonging to the sanctioned entities 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 one or more blocked persons are also blocked.” OFAC noted that U.S. persons are prohibited from participating in transactions with the sanctioned persons unless authorized by a general or specific license.

    On the same day, OFAC issued new frequently asked question guidance clarifying obligations for credit card operators with regard to payment cards issued by sanctioned Russian financial institutions. OFAC also published two Russia-related general licenses: (i) General License 28 authorizes certain transactions involving a public joint stock company that are “ultimately destined for or originating from Afghanistan”; and (ii) General License 29 authorizes the wind down of transactions involving the same public joint stock company.

    Find continuing InfoBytes coverage on the U.S. sanctions response to Russia’s invasion of Ukraine here.

     

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

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  • OFAC sanctions actors throughout the Western Balkans

    Financial Crimes

    On April 11, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order (E.O.) 14033 against seven individuals and one entity across four countries in the Western Balkans, which “is the second action OFAC has taken under E.O. 14033 targeting persons who threaten the stability of the region through corruption, criminal activity, and other destabilizing behavior.” OFAC also noted that the Department of State is designating individuals from North Macedonia and Bosnia and Herzegovina under Section 7031(c) of the Department of State, Foreign Operations, and Related Programs Appropriations Act, 2022, instituting what is commonly known as a visa ban. 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 OFAC Department of Treasury Of Interest to Non-US Persons OFAC Sanctions OFAC Designations SDN List Balkans

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  • OFAC sanctions Ireland-based criminal organization and members

    Financial Crimes

    On April 11, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13581 against an Ireland-based crime group, which OFAC considers “a murderous organization involved in the international trafficking of drugs and firearms,” seven of its key members, and three companies controlled or owned by key members of the organization. According to OFAC, the sanctions were the result of a collaborated effort between OFAC, the Drug Enforcement Administration, the U.S. Department of State, U.S. Customs and Border Protection, Ireland’s national police force (An Garda Síochána), the United Kingdom’s National Crime Agency, and the European Union Agency for Law Enforcement Cooperation. As a result of the sanctions, all assets belonging to 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. 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 OFAC Department of Treasury Of Interest to Non-US Persons OFAC Sanctions OFAC Designations SDN List Ireland

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  • OFAC sanctions Russian diamond mining and shipbuilding companies, and issues general licenses

    Financial Crimes

    On April 7, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions, pursuant to Executive Order 14024, against a Russian state-owned enterprise (SOE) and the world’s largest diamond mining company, which is also responsible for 90 percent of Russia’s diamond mining capacity. Additionally, the Department of State redesignated a Russian SOE open joint stock company, as well as its subsidiaries and board members. According to OFAC, the company develops and constructs most of the Russian military’s warships, likely including those used in Ukraine. OFAC further noted that it is “cutting off additional sources of support and revenue for the Government of the Russian Federation (GoR) to wage its unprovoked war against Ukraine.” As a result of the sanctions, all property and interests in property belonging to the sanctioned entities 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 one or more blocked persons are also blocked.” OFAC noted that U.S. persons are prohibited from participating in transactions with the sanctioned 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.”

    On the same day, OFAC issued several Russia-related general licenses: (i) General License 9C authorizes “transactions related to dealings in certain debt or equity”; (ii) General License 10C authorizes “certain transactions related to derivative contracts”; (iii) General License 21A authorizes “the wind down of Sberbank CIB USA, Inc. and Alrosa USA, Inc.”; (vi) General License 24 authorizes “the wind down of transactions involving public joint stock company Alrosa”; and (v) General License 25 authorizes “transactions related to telecommunications and certain internet-based communications.”

    Find continuing InfoBytes coverage on the U.S. sanctions response to Russia’s invasion of Ukraine here.
     

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

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  • OFAC sanctions North Koreans for development of WMDs

    Financial Crimes

    On April 1, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13382 against five entities for supporting the Democratic People’s Republic of Korea’s (DPRK’s) development of weapons of mass destruction (WMD) and ballistic missile programs in violation of multiple United Nations Security Council resolutions. According to OFAC, the sanctions target a DPRK WMD research and development organization, which is connected to the development of the DPRK’s intercontinental ballistic missile launches, along with four of its revenue generating subsidiaries. As a result of the sanctions, all property and interests in property of the sanctioned entities are blocked and must be reported to OFAC. OFAC noted that its regulations generally prohibit U.S. persons from participating in transactions with the designated entities, including transactions transiting the U.S. OFAC’s announcement further warned that any foreign financial institution that knowingly facilitates significant transactions or provides significant financial services for any of the designated individuals may be subject to U.S. correspondent account or payable-through account sanctions.

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

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  • OFAC sanctions Russian technology companies

    Financial Crimes

    On March 31, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced several new sanctions in response to Russia’s invasion of Ukraine. The new sanctions, issued pursuant to Executive Order 14024, target 21 entities and 13 individuals connected to the Russian Federation “as part of its crackdown on the Kremlin’s sanctions evasion networks and technology companies.” Additionally, OFAC has determined that three additional sectors of the Russian Federation’s economy are subject to sanctions, which permits OFAC to impose sanctions on any individual or entity determined to operate or have operated in any of those sectors. According to OFAC, one of the sanctioned entities is a technology company that exports over 50 percent of Russian microelectronics and is Russia’s largest chipmaker. This action follows OFAC’s March 24 designation of dozens of companies in Russia’s defense-industrial base that are directly involved in Russia’s invasion of Ukraine (covered by InfoBytes here). OFAC also expanded sanctions authorities to include the Russian aerospace, marine, and electronics sector. 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, and “any entities that are owned, directly or indirectly, individually or in the aggregate, 50 percent or more” by the targeted persons are blocked and must be reported to OFAC. Additionally, U.S. persons are prohibited from engaging in any dealings involving the property or interests in property of blocked or designated persons and entities, unless exempt or authorized by a general or specific OFAC license.

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

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  • OFAC sanctions IRGC-connected entities

    Financial Crimes

    On March 30, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order (E.O.) 13224, as amended, as well as E.O. 13382, against an Iran-based procurement agent and his network of companies that supported the Islamic Revolutionary Guard Corps Research and Self Sufficiency Jihad Organization (IRGC), the IRGC unit responsible for the research and development of ballistic missiles, as well as Iran’s Parchin Chemical Industries (PCI), an element of Iran’s Defense Industries Organization. Additionally, OFAC sanctioned an Iranian intermediary involved in the procurement of parts used to develop missile propellant on behalf of PCI.

    According to OFAC, the sanctions follow Iran’s missile attack on March 13 in Erbil, Iraq and an Iranian-enabled Houthi missile attack against a Saudi Aramco facility on March 25, in addition to other missile attacks by Iranian proxies against Saudi Arabia and the United Arab Emirates. 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, and “any entities that are owned, directly or indirectly, 50 percent or more” by the targeted persons are blocked and must be reported to OFAC. U.S. persons are generally prohibited from engaging in any dealings involving the property or interests in property of blocked or designated persons.

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

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  • OFAC sanctions individuals for raising funds supporting Nigerian terrorist group

    Financial Crimes

    On March 25, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13224, as amended, against six individuals connected to the Nigerian terrorist group Boko Haram. According to OFAC, the six individuals “were found guilty of establishing a Boko Haram cell in the United Arab Emirates (UAE) to raise funds for and provide material assistance to Boko Haram insurgents in Nigeria.” The sanctions follow “arrests, prosecutions, and designations in the UAE in September 2021, demonstrating the commitment of the Emirati government to using judicial measures and targeted financial sanctions to disrupt the flow of funds to these networks.” Under Secretary of the Treasury Brian Nelson stated that the U.S. is joining the UAE in targeting terrorist financing networks to ensure the Boko Haram network is unable to further move funds through the international financial system. As a result of the sanctions, all property and interests in property belonging to the sanctioned individuals in the U.S. or in the possession or control of U.S. persons, and “any entities that are owned, directly or indirectly, 50 percent or more” by the targeted individuals are blocked and must be reported to OFAC. Additionally, 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. 

    OFAC’s announcement further warned that “engaging in certain transactions with the individuals designated today entails risk of secondary sanctions” and that any foreign financial institution that knowingly facilitates significant transactions or provides significant financial services on behalf of a Specially Designated Global Terrorist may be subject to U.S. correspondent account or payable-through account sanctions.

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

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