Sanctions

Friday the Council of the European Union adopted a law covering EU-wide minimum rules for the prosecution of violation or circumvention of EU sanctions in member states. Certain actions will now be considered criminal offences in all member states, for example helping to bypass a travel ban, trading in sanctioned goods or performing prohibited financial activities. Inciting, aiding and abetting these offences can also be penalised. 

Dronemaker General Atomics Aeronautical Systems and General Dynamics Land Systems, have been sanctioned by the Chinese government for their sales to the government of Taiwan.    Last September China sanctioned Northrop Grumman and Lockheed Martin  on the same grounds. Missing from either announcement was Boeing, Taipei’s supplier of Harpoon anti-ship missiles.

The Treasury Department announced it is targeting a network facilitating shipments valued in the hundreds of millions for the Iranian military. Treasury's Office of Foreign Assets Control announced additional action against Iranian military revenue generation, targeting Oceanlink Maritime DMCC for facilitating the shipment of Iranian commodities on behalf of Iran's Armed Forces General Staff and Ministry of Defense and Armed Forces Logistics.

Commerce's BIS extended the Temporary Denial Order for Russian air cargo operator Aviastar-TU initially imposed in April 2022. Aviastar has continued to engage in conduct prohibited by the TDO and Regulations, including, but not limited to, on flights into and out of Russia from/to Hangzhou, China as well as domestically within Russia. 

On March 26, the United States hosted the inaugural meeting of the U.S.-Republic of Korea (ROK) bilateral Enhanced Disruption Task Force (EDTF), which is being established to counter illicit efforts by the Democratic People’s Republic of Korea (DPRK) to circumvent sanctions concerning the procurement of refined petroleum.   Through EDTF, the United States and ROK are pursuing a wide range of joint actions to disrupt DPRK refined oil procurement networks, including by exposing DPRK sanctions evasion activities, reviewing options for autonomous sanctions designations, and engaging private sector and third-party actors throughout the region who facilitate – either knowingly or unwittingly – the DPRK’s oil procurement networks.

Treasury’s Office of Foreign Assets Control (OFAC) is sanctioning six entities, one individual and two tankers that are based or registered in Liberia, India, Vietnam, Lebanon, and Kuwait that have engaged in facilitating commodity shipments and financial transactions for the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF), the Houthis, and Hizballah.

Treasury’s Office of Foreign Assets Control (OFAC) sanctioned 11 individuals and entities supporting the regime of Syrian President Bashar Al-Assad through the facilitation of illicit financial transfers and trafficking of illegal drugs, as well as the extraction and export of Syrian commodities.  

Treasury’s Office of Foreign Assets Control (OFAC) sanctioned a Chinese company responsible for a wide range a wide of "malicious cyber operations" targeting high-ranking U.S. government officials including staff at the White House; the Departments of Justice, Commerce, the Treasury, and State; members of Congress, including both Democrat and Republican Senators; the United States Naval Academy; and the United States Naval War College’s China Maritime Studies Institute. The organization also is responsible for cyber attacks on multiple Defense Industrial Base victims, including a defense contractor that manufactured flight simulators for the U.S. military, a Tennessee-based aerospace and defense contractor, and an Alabama-based aerospace and defense research corporation. Additionally, APT 31 actors gained unauthorized access to a Texas-based energy company, as well as a California-based managed service provider.

Treasury’s Office of Foreign Assets Control (OFAC) sanctioned thirteen entities and two individuals for operating in the financial services and technology sectors of the Russian Federation economy including persons developing or offering services in virtual assets that enable the evasion of U.S. sanctions. “Russia is increasingly turning to alternative payment mechanisms to circumvent U.S. sanctions and continue to fund its war against Ukraine,” said Under Secretary of the Treasury for Terrorism and Financial Intelligence, Brian E. Nelson.

Treasury’s Office of Foreign Assets Control (OFAC) targeted three procurement networks –– based in Iran, Türkiye, Oman, and Germany –– that have supported Iran’s ballistic missile, nuclear, and defense programs. These networks have procured carbon fiber, epoxy resins, and other missile-applicable goods for Iran’s arms proliferation activities.

Treasury’s Office of Foreign Assets Control (OFAC) designated two individuals and two entities for services they provided the Government of the Russian Federation (GoR) in connection with a foreign malign influence campaign, including attempting to impersonate legitimate media outlets.   Specifically, via their companies,  SDA and Structura, the two created a sprawling network of over 60 websites that impersonated legitimate news organizations, and which used misleading social media accounts to amplify the content of the spoofed websites.

Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Wendy Carolina Morales Urbina, Nicaragua’s Attorney General, for being complicit in the Ortega-Murillo regime’s oppression.  In her capacity as Attorney General, Morales Urbina is responsible for enabling the Ortega-Murillo regime to confiscate real property formerly belonging to independent media outlets, international organizations, and political prisoners

The Commerce Department’s Bureau of Industry and Security (BIS) released a final rule to impose additional restrictions under the Export Administration Regulations (EAR) on persons identified under fourteen sanctions programs, on the List of Specially Designated Nationals and Blocked Persons (SDN List) maintained by the Department of the Treasury’s Office of Foreign Assets Control (OFAC). “Today’s action will further our already strong coordination with the Treasury Department to prevent foreign actors from obtaining the items and financing they seek to conduct activities that threaten U.S. national security and foreign policy interests,” said Under Secretary of Commerce for Industry and Security Alan Estevez.

Treasury’s Office of Foreign Assets Control (OFAC) designated Diego Macedo Gonçalves do Carmo (Gonçalves), a member of Primeiro Comando da Capital (PCC), a Brazil-based criminal organization sanctioned pursuant to counter narcotics authorities. The PCC is the most notorious organized crime group in Brazil and among the largest in Latin America, and Gonçalves is a key operative responsible for laundering hundreds of millions of dollars for the organization.

The United States is designating sixteen entities and individuals in a transnational network that spans the Horn of Africa, United Arab Emirates, and Cyprus, for facilitating financing and money laundering for the al-Shabaab terrorist organization, a terrorist group responsible for some of the worst terrorist attacks in East Africa’s modern history.

U.S. Senator Marco Rubio (R-FL) introduced the Sanctions Recovery Act to "incentivize" OFAC to strictly enforce sanctions. "OFAC has not been as aggressive in sanctions enforcement as it should be." The bill would allow the agency to acquire 5 percent of foreign assets seized as well as of sanctioned fines. The amount collected would benefit salaries and administrative costs, and thus allow OFAC to increase sanctions and recompense Treasury for further enforcement efforts.

OFAC is amending and reissuing the Global Magnitsky Sanctions Regulations (31 CFR part 583) as a more comprehensive set of regulations that includes additional interpretive guidance and definitions, general licenses, and other regulatory provisions that will provide further guidance to the public. Further, OFAC is adding the Uyghur Human Rights Policy Act of 2020, as amended to the authority citation of 31 CFR part 583. Due to the number of regulatory sections being updated or added, OFAC is reissuing the Regulations in their entirety.

Treasury’s Office of Foreign Assets Control (OFAC) took additional action to target shipments of Iranian commodities undertaken by the network of Iran-based, Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF)-backed Houthi financial facilitator Sa’id al-Jamal. The most recent action targets two Hong Kong- and Marshall Islands-based ship owners and two vessels for their role in shipping commodities on behalf of al-Jamal, and follows a February 27 action targeting a related vessel, the ARTURA. 

Treasury’s Office of Foreign Assets Control (OFAC) designated two individuals and five entities associated with the Intellexa Consortium for their role in developing, operating, and distributing commercial spyware technology used to target Americans, including U.S. government officials, journalists, and policy experts. Since its founding in 2019, the Intellexa Consortium has acted as a marketing label for a variety of offensive cyber companies that offer commercial spyware and surveillance tools to enable targeted and mass surveillance campaigns.

Treasury is designating three entities and eleven individuals, including President Emmerson Mnangagwa, Vice President Constantino Chiwenga, Brigadier General (Retired) Walter Tapfumaneyi, and …

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