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On January 8, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions against an Iraqi militia leader for his alleged connection to serious human rights abuses. According to OFAC, the sanctions are taken pursuant to Executive Order 13818, which implements the Global Magnitsky Human Rights Accountability Act and “targets perpetrators of serious human rights abuse and corruption.” As a result of the sanctions, all of the militia leader’s property and interests in property that are in the United States, as well as any entities that are owned 50 percent or more by him are blocked and must be reported to OFAC. Additionally, OFAC regulations “generally prohibit” U.S. persons from participating in financial transactions with the individual and blocked entities.
OFAC sanctions front company network for providing financial support to Islamic Revolutionary Guards
On March 26, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13224 against 20 Iran- and Iraq-based front companies and individuals for providing financial support to the Islamic Revolutionary Guards Corps-Qods Force, as well as certain Iranian-backed terrorist militias in Iraq. Among other activities, OFAC alleged that the designated companies and individuals laundered money through Iraqi front companies, sold Iranian oil to the Syrian regime, and smuggled weapons to Iraq and Yemen. Pursuant to the sanctions, “all property and interests in property of these persons that are in or come within the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC.” OFAC noted that its regulations “generally prohibit” U.S. persons from participating in transactions with the designated persons and warned foreign financial institutions that if they knowingly conduct or facilitate significant transactions for any of the designated persons, they may be “subject to U.S. correspondent account or payable-through account sanctions.”
OFAC announces anti-terrorism sanctions targeting foreign banks that transact with designated terrorists
On September 10, the U.S. Treasury Department's Office of Foreign Assets Control (OFAC) announced the designation of 15 leaders, individuals, and entities affiliated with terror groups, pursuant to the newly issued Executive Order (E.O.) 13886, “Modernizing Sanctions to Combat Terrorism,” which updates E.O. 13224. E.O. 13886 provides Treasury and the State Department with “new tools” to identify and designate perpetrators. Most notably, under E.O. 13886, foreign financial institutions are now subject to secondary sanctions, allowing OFAC to prohibit or impose strict conditions on the opening or maintaining in the U.S. of a correspondent account or a payable-through account by any foreign financial institution that knowingly facilitates a significant transaction for any Specially Designated Global Terrorist (SDGT), or a person acting on behalf of or at the direction of, or owned or controlled by, a SDGT.
As a result of the sanctions, all property and interests in property of the sanctioned targets subject to U.S. jurisdiction are blocked and must be reported to OFAC. U.S. persons are also generally prohibited from entering into transactions with designated persons. Finally, OFAC warns that persons that engage in transactions with the designated individuals “may themselves be exposed to sanctions or subject to an enforcement action.”
On July 18, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13818 against two militia figures and two former Iraqi governors for alleged human rights abuses or corruption violations of the Global Magnitsky Human Rights Accountability Act. According to OFAC, the four individuals committed the corruption-and abuse-related actions “in areas where persecuted religious communities are struggling to recover from the horrors inflicted on them by ISIS.” As a result of the sanctions, all property and interests in property of the designated persons within U.S. jurisdiction must be blocked and reported to OFAC. OFAC notes that its regulations “generally prohibit” U.S. persons from participating in transactions with these individuals and entities.
On April 15, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions against seven individuals and one entity for allegedly providing financial support to the Islamic State of Iraq and Syria (ISIS) operating in Europe, Africa, and the Middle East. According to OFAC, six of the designated individuals, as well as the identified entity, belong to a key ISIS financial facilitation group, which uses “money service businesses to circumvent the formal banking sector” and move funds through financial cells around the globe. The seventh designated individual is a financial facilitator in East Africa. As a result, all property and interests in property of the sanctioned entity and individuals, and of any entities owned 50 percent or more by them subject to U.S. jurisdiction, are blocked and must be reported to OFAC. U.S. persons are also generally prohibited from entering into transactions with the sanctioned entity and individuals.
OFAC sanctions Iranian bank officials, Iraqi bank, and others for moving millions of dollars to Hizballah
On May 15, U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced it was imposing sanctions on the governor and a senior official of the Central Bank of Iran, an Iraqi bank and its chairman, and a key Hizballah official, for allegedly funneling millions of dollars on behalf of the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) to Hizballah. Pursuant to Executive Order 13224, which “provides a means by which to disrupt the financial support network for terrorists and terrorist organizations by authorizing the U.S. government to designate and block the assets of foreign individuals and entities that commit, or pose a significant risk of committing, acts of terrorism,” the individuals and entities were designated as Specially Designated Global Terrorists. The actions, which follow a May 10 action taken against individuals and entities who materially assisted in the conversion of millions of U.S. dollars to fund IRGC-QF’s malignant activities, “seek to stifle Iran’s ability to abuse the U.S. and regional financial systems.”
However, OFAC clarified that sanctions on the officials of the Central Bank of Iran do not extend to the bank itself. Following President Trump's decision to cease participation by the U.S. government in the Joint Comprehensive Plan of Action, sanctions on the bank will be re-imposed August 7, and on November 5, additional sanctions will be re-imposed on persons knowingly engaging in certain significant transactions with the Central Bank of Iran.
Visit here for additional InfoBytes coverage on Iranian sanctions.
Recently, OFAC announced implementation of sanctions against several entities and individuals designated for, among others, materially assisting, sponsoring, or providing financial support to certain foreign entities. In addition, OFAC updated its list of Specially Designed Nations (SDN) and announced a settlement agreement with a Canadian-based motor vehicle finance company.
North Korea Suppliers of Weapons Proliferation Programs. On June 1, OFAC announced it was taking action against six entities and three individuals in response to their involvement in North Korea’s continued efforts to develop weapons of mass destruction (WMD). The announcement targets the country’s military, nuclear, and WMD programs, in addition to its overseas financial operations. The sanctions prohibit any U.S. individual from dealing with the designees, and further states that “any property or interests in property of the designated persons in the possession or control of U.S. persons or within the United States must be blocked.” John E. Smith, the Director of OFAC, stated, “Treasury is working with our allies to counter networks that enable North Korea’s destabilizing activities, and we urge our partners to take parallel steps to cut off their funding sources.” These sanctions are in addition to those imposed earlier in April on eleven North Koreans and one associated entity (see previous InfoBytes coverage here).
Iraq-Based Chemical Weapons Developers. On June 12, OFAC announced, for the first time, designations against individuals involved in the development of ISIS’ chemical weapons. The sanctions were pursuant to Executive Order 13224, which “provides a means by which to disrupt the financial support network for terrorists and terrorist organizations by authorizing the U.S. government to designate and block the assets of foreign individuals and entities that commit, or pose a significant risk of committing, acts of terrorism.” The property and interests in property of the two individuals identified in the designations, subject to U.S. jurisdiction, are blocked, and “U.S. persons are generally prohibited from engaging in transactions with them.”
Settlement Agreement with Motor Vehicle Finance Company. On June 8, OFAC announced it had reached a settlement with a motor vehicle finance company as a result of transactions by its Canadian based subsidiary. The enforcement action claims the majority-owned subsidiary, which “specializes in various forms of financing in the [U.S.] for purchasers, lessees, and authorized independent [auto] dealers,”—between 2011 and 2014—allegedly violated 13 Cuban Assets Control Regulations by leasing vehicles to the Cuban Embassy in violation of OFAC’s Blocked Persons and SDN list, which prohibited transactions with Cuban government entities. The company voluntarily self-disclosed the alleged violations and agreed to remit $87,255 to settle its potential civil liability.
Foreign Narcotics Kingpin Sanctions. On May 24 and 25, OFAC made additions to the SDN list, which designates individuals and companies who are prohibited from dealing with the U.S. and whose assets are blocked. Transactions are prohibited if they involve transferring, paying, exporting, or otherwise dealing in the property or interest in property of an entity or individual on the SDN list. Additions to the list were made under the Foreign Narcotics Kingpin Sanctions Regulations against several Mexican and Colombian individuals and entities.
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