Sanctions

Treasury’s Office of Foreign Assets Control (OFAC) sanctioned two companies - one in Russia and one in the Central African Republic (CAR) - for their efforts in advancing Russia’s malign …

The Departments of Justice, Commerce, and Treasury’s Office of Foreign Assets Control, have issued a Tri-Seal Compliance Note: Obligations of foreign-based persons to comply with U.S. sanctions and export control laws. The Note highlights the applicability of U.S. sanctions and export control laws to persons and entities located abroad, as well as the enforcement mechanisms that are available for the U.S. government to hold non-U.S. persons accountable for violations of such laws, including criminal prosecution.

Treasury's Office of Foreign Asset Control issued notices renaming and modifying sanctions in Sudan, updating Venezuela FAQs, and making grammatical changes to update existing sanctions.

Treasury’s Office of Foreign Assets Control (OFAC), in coordination with the United Kingdom, has sanctioned the Deputy Commander of Iran’s Islamic Revolutionary Guard Corps-Qods Force, a Yemeni militant, and two cargo vessels carrying Iranian petroleum.

Treasury’s Office of Foreign Assets Control (OFAC) has targeted Joint Stock Company Sovcomflot, Russia’s state-owned shipping company and fleet operator. In addition to designating Sovcomflot, OFAC is identifying 14 crude oil tankers as property in which Sovcomflot has an interest.

The Oil Price Cap permits service providers in Coalition countries to support the Russian oil trade only if the oil was sold at or below a specific cap. A Treasury policy note looks at the difference that the price cap is continuing to make three months into the second phase, as the coalition continues to take action to enforce the prohibition against the use of G7 services outside the cap.

Joining British and European allies, the US imposed a further raft of sanctions on Russia and her enablers. Treasury’s Office of Foreign Assets Control (OFAC) is sanctioning almost 300 individuals and entities. This is the largest number of sanctions imposed since Russia’s 2022 invasion of Ukraine. State is designating three Government of Russia officials in connection with Aleksey Navalny’s death; together, Treasury and State are sanctioning over 500 targets. The Department of Commerce is also adding more than 90 companies to the Entity List.

The European Union announced another round of sanctions on Russia and her allies, extending the reach to include Chinese and Indian firms complicit in avoiding existing restrictions.  The new measures focus on the procurement network supporting Russia's military, especially the supply chain to make drones. Twenty-seven companies were added to the Annex IV list, which means European firms cannot sell dual-use goods to them.

The Department of the Treasury's Office of Foreign Assets Control (OFAC) is issuing Russia-related General License 83A, "Authorizing Certain Transactions Related to Imports of Certain Categories of Fish, Seafood, and Preparations Thereof Prohibited by Executive Order 14068." The General License permits importation into the United States of seafood derivative products that were loaded onto a vessel at the port of loading prior to  February 20, 2024, pursuant to written contracts agreements entered into prior to December 22, 2023, are authorized through May 31, 2024.

Representatives of the U.S. Departments of State, Commerce, and Treasury, along with delegations from the UK and Ukraine, joined senior EU and member state government officials for a Sanctions Coordinators Forum in Brussels Tuesday. "We reaffirmed our shared commitment to supporting Ukraine’s sovereignty and opposing Russia’s aggression and that sanctions are a key tool in that effort. The delegations discussed the use of targeted sanctions to deter and disrupt malign Russian activity and to demonstrate our readiness to take action to defend international norms," according to a State Department readout. The EU Statement was more comprehensive:

The Department of the Treasury's Office of Foreign Assets Control (OFAC) is amending the North Korea Sanctions Regulations to amend or add general licenses to facilitate certain humanitarian-related and journalistic activities. These changes include: additional non-governmental organization (NGO) activities, removal of dual licensing burden, expansion of authorization for the exportation or reexportation of certain food, medicine, and other agricultural and medical items, and a new G/L for Journalists.

Treasury’s Office of Foreign Assets Control (OFAC) sanctioned a procurement network responsible for facilitating the illegal export of goods and technology from over two dozen U.S. companies to end-users in Iran, including the Central Bank of Iran (CBI), which is designated for its role in providing financial support to the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) and Hizballah. Among sanctioned firms are an Iranian subsidiary of Iran’s Central Bank that most recently developed the Central Bank Digital Currency platform for the bank; a UAE-based front company, which acquired U.S. tech for the Central Bank of Iran and the front company’s CEO, as well as a Turkey-based affiliate firm that also made purchases that ended up in Iran.

Treasury’s Office of Foreign Assets Control (OFAC) has taken its second price cap enforcement action of 2024, imposing sanctions on four entities and identifying one vessel as blocked property. OFAC is also issuing two new determinations that implement G7 commitments to ban the importation of Russian diamonds.

The Justice Department announced the unsealing of three federal cases, across two U.S. Attorneys’ Offices, as the most recent in a series of efforts to combat the illicit trafficking of Iranian oil that funds Iran’s Islamic Revolutionary Guard Corps (IRGC), and its Qods Force (IRGC-QF), Iran’s primary mechanism for cultivating and providing lethal support to terrorist organizations abroad Seven defendants are charged in the Southern district of New York, along with the seizure of $108 million. Two more defendants were named in a case filed in the District of Columbia, along with a forfeiture complaint for 500,000 barrels of oil in transit.

The Department of Defense released an updated blacklist with more than a dozen new Chinese companies on it, including memory chip maker YMTC, artificial intelligence company Megvii, LiDAR maker Hesai Technology and tech company NetPosa.   Section 1260H of the William M. (Mac) Thornberry NDAA for FY21 (Pub. L. 116–283) directs the Secretary of Defense to continue to list “Chinese military companies” (CMCs) annually until December 31, 2030.

Swiss-based, Singapore-registered, and US Government-funded commodity trader Trafigura Group announced that one of their cargos of Russian fuel was struck by a missile as it left the Red …

October's six-month relief of sanctions on trading with the government of Venezuela appears in jeopardy, as conditions for their continuation appear not to have been met. Bipartisian immigration reform, however, has been supported by increased civil aviation cooperation between Washington and Caracas, while US and European oil companies have been assiduously reviving production in Venezuela's oilfields.  

Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson convened a roundtable with representatives of non-governmental organizations, international organizations, and U.S. government implementers to discuss the designation of Ansarallah (“Houthis”) and the Office of Foreign Assets Control (OFAC) issuance of five additional general licenses.   Treasury reiterates that Yemen is not subject to jurisdiction-based sanctions, nor will it become subject to jurisdiction-based sanctions on February 16, 2024.  U.S. sanctions do not stand in the way of humanitarian activities and the delivery of essential commercial goods to the people of Yemen

The Commerce Department’s Bureau of Industry and Security (BIS) has expanded the scope of the EAR’s Russian and Belarusian Industry Sector Sanctions by adding 95 6-digit Harmonized Tariff Schedule (HTS) codes to the list of items requiring a license for export, reexport, or transfer (in-country) to Russia or Belarus. The expanded list of items includes certain chemicals, lubricants, and metals, and it covers the entirety of Chapter 88 of the HTS (aircraft, spacecraft, and parts thereof).

OFAC has released the first video in its “OFAC Basics” video series.  The OFAC Basics: Sanctions List Search video provides viewers with a brief tutorial on how to use OFAC’s Sanctions List Search Tool and recommended steps for assessing a potential match to one of OFAC’s published sanctions lists.  

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