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  • OFAC designates entities and individuals, issues general license and related Ethiopian FAQs

    Financial Crimes

    On November 12, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order (E.O.) 14046 against four entities and two individuals associated with the military conflict and human rights crisis in Ethiopia. OFAC noted that the E.O., which was signed by President Biden on September 17, authorized targeting of actors that contribute to the ongoing crisis in Ethiopia and is not directed at Ethiopian or Eritrean people (covered by InfoBytes here). As a result of the sanctions, all property and interests in property belonging to the sanctioned entities and individuals subject to U.S. jurisdiction are blocked and must be reported to OFAC. OFAC further noted that no entity is to be blocked “pursuant to E.O. 14046 solely because it is owned in whole or in part, directly or indirectly, by one or more sanctioned persons, unless the entity is itself a sanctioned person.”

    The same day, OFAC issued Ethiopia General License 4, “Authorizing the Wind Down of Transactions Involving Hidri Trust or Red Sea Trading Corporation,” which are two of the four entities for which sanctions were announced.  Ethiopia General License 4 authorizes “all transactions and activities prohibited by Executive Order (E.O.) 14046 that are ordinarily incident and necessary to the wind down of transactions involving Hidri Trust or Red Sea Trading Corporation” through December 14, provided certain criteria are met. OFAC also updated FAQ 927, which provides clarification on non-U.S. persons’ risk exposure to U.S. sanctions for engaging in transactions and activities that would be authorized for U.S. persons pursuant to the prior E.O. of September 17. Additionally, OFAC published two new FAQs (935 and 936), which provide further information on Ethiopia-related sanctions.

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

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  • President Biden issues executive order addressing crisis in Ethiopia

    Financial Crimes

    On September 17, President Biden signed a new Executive Order (E.O.), Imposing Sanctions on Certain Persons with Respect to the Humanitarian and Human Rights Crisis in Ethiopia, that declares a national emergency with respect to the humanitarian and human rights crisis in northern Ethiopia. The E.O. provides the Secretary of the Treasury, in consultation with the Secretary of State, with the authority “to impose a range of targeted sanctions on persons determined, among other things, to be responsible for or complicit in actions or policies that expand or extend the ongoing crisis or obstruct a ceasefire or peace process in northern Ethiopia or commit serious human rights abuse.” Concurrently, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued three new general licenses, GLs 1, 2, and 3, which authorize official activities associated with certain international organizations and entities, certain nongovernmental organizations’ activities, and certain transactions associated with the exporting or reexporting of agricultural commodities, food, medicine, and medical items. OFAC also published six related FAQs (see FAQs 922923924925926, and 927), which provide additional clarity concerning the non-application of OFAC’s 50 Percent Rule to property and interests in property of persons blocked pursuant to the new E.O., as well as guidance on activities authorized by the new GLs.  

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

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