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OFAC sanctions Russians for supporting DPRK’s WMD programs
On March 11, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13687 against two individuals and three entities based in Russia for allegedly supporting the Democratic People’s Republic of Korea’s (DPRK) “ongoing development of its weapons of mass destruction (WMD) and ballistic missile programs in violation of multiple United Nations Security Council resolutions.” The action specifically “targets a group of foreign individuals and companies that aid a DPRK defense industry-related procurement agent in Russia.” As a result of the sanctions, all property and interests in property of the sanctioned persons subject to U.S. jurisdiction 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 persons. 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, and that persons found to have engaged in certain transactions with the designated persons “may themselves be exposed to designation.”
OFAC sanctions Hizballah financiers in Guinea
On March 4, the U.S. Treasury Department’s Office of Foreign Assets Control announced sanctions pursuant to Executive Order 13224, as amended, against two Hizballah-affiliated financial facilitators operating in Guinea. The action is intended to disrupt Hizballah’s business network in West Africa, which relies on bribes and other corrupt activity, OFAC stated, and is part of “Treasury’s ongoing efforts to target the terrorist group’s international commercial activities and its global network of financiers, supporters, donors, and facilitators, which enable Hizballah to persistently threaten the security, stability, and prosperity of Lebanon and other jurisdictions.” As a result of the sanctions, all transactions by U.S. persons or in the U.S. that involve any property or interests in property of the designated persons are prohibited. 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.” U.S. persons are generally 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 further warned that the agency “can 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 knowingly conducted or facilitated any significant transaction on behalf of a [Specially Designated Global Terrorist.]”
OFAC sanctions ISIS facilitators
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.
OFAC sanctions Belarusians for supporting Russian invasion of Ukraine
On February 24, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions against 24 Belarusian individuals and entities due to Belarus’s support for, and facilitation of, Russia’s invasion of Ukraine. The sanctions focus on Belarus’s defense sector and financial institutions, which have close ties to Russia. OFAC stressed that the “Belarusian economy is highly dependent on key Russian financial institutions and their subsidiaries” and that restrictions imposed against the Public Joint Stock Company Sberbank of Russia, VTB Bank Public Joint Stock Company, and State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank, combined with the new measures taken against Belarusian banks “target nearly one-fifth of the country’s entire financial sector.” Specifically, OFAC designated two significant state-owned banks that directly or indirectly finance or conduct activity on behalf of the Government of Belarus (GoB). “Sanctioning these two GoB-owned banks, in addition to Russia-related restrictions imposed on three other systemically important Belarusian financial institutions, means that a significant portion of the Belarusian financial sector is now subject to U.S. sanctions,” OFAC stated. As a result of the sanctions, all property and interests in property belonging to the sanctioned individuals and entities 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 blocked persons are blocked and must be reported to OFAC. 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 numerous related directives and general licenses that provide for multiple exceptions, along with several new and updated frequently asked questions. A Buckley Special Alert provides additional details related to the evolving nature of the U.S. sanctions response to Russia’s invasion of Ukraine.
OFAC sanctions network connected to Houthis in Yemen
On February 23, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order (E.O.) 13224 against members of an international network for funding the Houthis’ war against Yemen and threatening civilians and infrastructure in neighboring states. According to OFAC, the group is led by Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) and a Houthi financier, which has transferred money to Yemen via a complex international network of intermediaries in support of the Houthis’ attacks. As previously covered by InfoBytes, in June 2021, OFAC designated the Houthi financier and members of his network pursuant to E.O. 13224, for their role in generating revenue through the sale of commodities such as petroleum to fund the Houthis. OFAC also noted that “the Houthis continue their destructive campaign inside Yemen, and have repeatedly launched ballistic missiles and unmanned aerial vehicles that have struck civilian infrastructure in neighboring states, resulting in civilian casualties.” 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 the individuals 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 or their blocked property, and foreign financial institutions that knowingly participate in significant transactions related to the designated individuals risk exposure to sanctions that could discontinue their access to the U.S. financial system or block their property or interests in property under U.S. jurisdiction.
OFAC sanctions additional Mexican national linked to narcotics trafficking
On February 17, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 14059 against a Mexican national for his role in facilitating various illicit activities in Puerto Vallarta, Jalisco, Mexico on behalf of the Cartel de Jalisco Nueva Generacion (CJNG). CJNG “uses this renowned tourist destination as a strategic stronghold not only for drug trafficking but also money laundering, extortion, kidnappings, and assassinations,” Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson stated. “Treasury will continue working with U.S. partners and the Mexican government to expose and disrupt CJNG, from its leadership to its facilitators.” The designated individual joins other previously designated businesses and individuals linked to CJNG for playing “critical roles in CJNG’s drug trafficking activities, including money laundering.” As a result of the sanctions, the designated individual’s 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 individual.
OFAC sanctions drug traffickers
On February 10, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 14059 against two individuals for materially contributing to the illicit activities of major Mexican cartels to traffic drugs into the U.S. According to OFAC, the action, which was the result of collaboration between OFAC and the Drug Enforcement Administration, provides that all property and interests in property of sanctioned individuals in the U.S. or in the possession or control of U.S. persons must be blocked and reported to OFAC. OFAC notes that its regulations generally prohibit all transactions by U.S. persons that involve any property or interests in property of designated or otherwise blocked persons.
OFAC sanctions Indonesian NGO
On February 3, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13224 against a non-governmental organization established by an Indonesia-based designated terrorist group for the purpose of providing financial support to extremists in Syria under the cover of humanitarian aid. According to Under Secretary of the Treasury for Terrorism and Financial Intelligence, Brian E. Nelson, “[t]he United States is taking this action to expose and disrupt [the terrorist group’s] deceptive efforts to use a purported ‘humanitarian organization’ for illicit purposes as a front for collecting and transferring funds.” Nelson added that “Treasury will continue to work with foreign partners to protect the non-profit sector from abuse by terrorist groups that disguise illicit finance flows as humanitarian activity.” As a result of the sanctions, all property and interests in property of the sanctioned entity subject to U.S. jurisdiction 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, unless exempt or authorized by a general or specific OFAC license. OFAC further warned that the agency “can 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 knowingly conducted or facilitated any significant transaction on behalf of a Specially Designated Global Terrorist.”
OFAC sanctions officials and entities connected to Burmese military
On January 31, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 14014 against seven individuals and two entities connected to Burma’s military regime. The sanctions coincide with the one-year anniversary of the military coup d’etat of Burma’s democratically elected government, and are part of a joint action taken with the UK and Canada. Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson stated that the U.S. “will continue to target those responsible for the coup and ongoing violence, enablers of the regime’s brutal repression, and their financial supporters.” As a result of the sanctions, all property and interests in property belonging to the identified 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 generally prohibited from engaging in any dealings involving the property or interests in property of blocked or designated individuals, unless exempt or authorized by a general or specific license. Prohibitions “include 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.”
OFAC sanctions additional Hizballah financiers
On January 21, the U.S. Treasury Department’s Office of Foreign Assets Control announced sanctions pursuant to Executive Order 13224 against a Hizballah-affiliated financial facilitator, along with members of an international network of facilitators and companies connected to both the designated individual and a Hizballah-linked financial facilitator sanctioned by OFAC on January 18 (covered by InfoBytes here). According to OFAC, the designated persons evaded sanctions efforts in order to help Hizballah gain access to the international financial system and raise funds to support acts of terrorism and other illicit activities. “Today’s action exposes and targets Hizballah’s misuse of the international financial system to raise and launder funds for its destabilizing activities as the Lebanese people suffer during an unprecedented economic crisis in Lebanon,” Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson stated. “Treasury is committed to disrupting Hizballah’s illicit activity and attempts to evade sanctions through business networks while the group doubles down on corrupt patronage networks in Lebanon.”
As a result of the sanctions, all transactions by U.S. persons or in the U.S. that involve any property or interests in property of designated or otherwise blocked persons are generally prohibited. 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.” U.S. persons are generally 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 further warned that the agency “can 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 knowingly conducted or facilitated any significant transaction on behalf of a Specially Designated Global Terrorist.”