Treasury’s Office of Foreign Assets Control (OFAC) is taking its first oil price cap enforcement action of 2024, targeting a shipping company linked to a price cap violation. OFAC is also issuing Russia-related General License 13H , "Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024," and Russia-related General License 86, "Authorizing Limited Safety and Environmental Transactions Involving Certain Persons or Vessels Blocked on January 18, 2024." OFAC is also amending Frequently Asked Question 1157. 

Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Alberto Pimentel Mata for his role in exploiting the Guatemalan mining sector through widespread bribery schemes, including schemes related to government contracts and mining licenses.

Treasury and State announced further sanctions on shipping activities related to the Houthi rebels in Yemen and the Russian Military. OFAC also lifted sanctions on a Gulfstream G650 business jet associated with oligarch Suleyman Kerimov. OFAC added four tankers two companies in Hong Kong and the United Arab Emirates for shipping Iranian commodities on behalf of the network of Iran-based, Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF)-backed Houthi financial facilitator Sa’id al-Jamal.  Earlier in the week OFAC added several entities and indigenous (Ilyushin and Antonov) aircraft complicit in the transfer to Russia and testing of DPRK-origin ballistic missiles by Russia since late November 2023.

A New Hampshire charity delivering humanitarian aid to Syria was sentenced in federal court for export offenses.   NuDay was sentenced December 28 by U.S. District Court Judge Joseph N. Laplante to five years of probation, the maximum penalty for an organizational defendant.  NuDay was also ordered to pay a $25,000 fine.  On September 8, 2023, NuDay pleaded guilty to three counts of Failure to File Export Information.

Treasury’s Office of Foreign Assets Control (OFAC) designated one individual and three entities responsible for facilitating the flow of Iranian financial assistance to Houthi forces in Yemen. Among those designated today is the head of the Currency Exchangers Association in Sana’a, and three exchange houses in Yemen and Türkiye.

China announced it will impose sanctions on a United States company and two individuals in reaction to similar measures taken by the U.S. against Chinese officials and entities. The December 26 sanctions target Kharon, a U.S. intelligence data firm, its director of investigations Edmund Xu, and former researcher Nicole Morgret. These sanctions are a response to allegations and measures concerning the situation in the Xinjiang Uygur autonomous region.

The United States and other countries participating in the Price Cap Coalition announced new rules aimed at making it harder to Russia to circumvent the price cap imposed on Russian oil in response to its invasion of Ukraine. “These changes will further complicate efforts by Russian exporters to circumvent the price cap while deceiving Coalition service providers, and further raise costs for any Russian exporters that need premier services but are unwilling to sell oil under the cap,” according to the coalition's announcement December 21.. The changes include requiring that relevant Coalition service providers receive attestations from their counterparties each time they lift or load Russian oil. The coalition also is introducing changes that will require supply chain participants with access to itemized ancillary costs (e.g., insurance and freight) to share these upon request with entities further down the supply chain.

The United States announced new listings of four Nicaraguan, four Guatemalan, three Honduran, and three Salvadoran individuals under the Section 353 Corrupt and Undemocratic Actors report.  …

The Administration imposed sanctions on 10 entities and four individuals in order to disrupt a procurement network across the Middle East and East Asia supporting Iran’s unmanned aerial vehicle production. Being targeted by the Treasury Department’s Office of Foreign Assets Control December 19 are entities and individuals based in Iran, Malaysia, Hong Kong and Indonesia.

The European Council adopted Monday a twelfth package of economic and individual restrictive measures in view of the continued Russian war of aggression against Ukraine.

Friday, the President signed a new Russia-related Executive Order advising financial institutions and payments processors that "Foreign financial institutions that conduct or facilitate significant transactions or provide any service involving Russia’s military-industrial base run the risk of being sanctioned by OFAC." Under these new authorities, OFAC can impose full blocking sanctions on, or prohibit or restrict the maintenance of correspondent accounts in the United States for, foreign financial institutions.

In coordination with Treasury and Justice, the State Departemnt  named three Chinese firms for the proliferation ofthe proliferation of weapons of mass destruction and the means of delivering them. The three firms, based in Hong Kong, Beijing and Changzhou, respectively were cited by the Under Secretary of State for Arms Control and International Security added the entities to the the list of Specially Designated Nationals and Blocked Persons.

Treasury's Office of Foreign Assets Control (OFAC) and the State Departemnt announced sanctions on over 100 entities and individuals including those engaged in sanctions evasion in numerous third countries, complicit in furthering Russia’s ability to wage its war against Ukraine, and responsible for bolstering Russia’s future energy production and export capacity. The December 11 action highlights Russia’s utilization of Türkiye, the United Arab Emirates (UAE), and the People’s Republic of China (PRC), as well as the use of complex transnational networks and third-country cut-outs, to acquire much-needed technology and equipment for its war economy.

The Council and the European Parliament concluded their negotiations for an EU law which introduces criminal offences and penalties for the violation of EU sanctions. This directive ensures that those who violate or circumvent EU sanctions will be prosecuted.  The law lays down that member states will need to define certain actions as criminal offences.

A California man was sentenced to 18 months in federal prison for conspiring to procure and illegally ship high-end computer servers from the United States to Iran.

Treasury’s Office of Foreign Assets Control (OFAC) is designating 11 entities and seven individuals pursuant to Executive Order (E.O.) 14038 and one individual pursuant to E.O. 14024. This action increases the pressure on Alyaksandr Lukashenka’s authoritarian regime for its suppression of Belarus’s democratic civil society, financial enrichment of the Lukashenka family, and complicity in Russia’s war against Ukraine.

Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Luis Miguel Martinez Morales for his role in corruption in Guatemala wherein he engaged in widespread bribery schemes, including schemes related to government contracts. Martinez is the former head of the now-defunct Centro de Gobiernoa powerful quasi-cabinet level agency created by Guatemalan President Alejandro Giammattei at the start of his administration.  

Legislation authorizing the Justice Department to more quickly seize high-value assets owned by sanctioned Russian oligarchs and transfer the funds to Ukraine is being sponsored by a bipartisan group of lawmakers. The Asset Seizure for Ukraine Reconstruction Act would allow Justice to seize high-value assets owned by sanctioned Russian oligarchs more quickly through existing administrative forfeiture processes and transfer the proceeds from those assets to assistance for Ukraine.

In the event conflict with China warrents further sanctions, the U.S. may find its leverage weaker than desired, according to a new report from the Center for a New American Security (CNAS).   No Winners in This Game: Assessing the U.S. Playbook for Sanctioning China by Emily Kilcrease illuminates the severe constraints on U.S. sanctioning capabilities, particularly if the United States attempts to act unilaterally without key partners.  …

OFAC sanctioned eight foreign-based Democratic People’s Republic of Korea’s (DPRK) agents that facilitate sanctions evasion, including revenue generation and missile-related technology procurement that support the DPRK’s weapons of mass destruction (WMD) programs. Additionally, OFAC sanctioned cyber espionage group Kimsuky for gathering intelligence to support the DPRK’s strategic objectives.

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