Sanctions

In a coordinated effort with Canada and the United Kingdom, the Treasury Department’s Office of Foreign Assets Control published a new directive Oct. 31 that prohibits certain financial services by US persons to or for the benefit of Myanma Oil and Gas Enterprise, as well as five military regime appointed officials and officers.

The U.S. Treasury's Office of Foreign Assets Control (OFAC) recently added eight individuals and four entities to its specially designated nationals list in response to the Hamas attacks on Oct. 7.

A bipartisan group of U.S. lawmakers has introduced legislation calling on the Biden administration to impose sanctions on 49 top Hong Kong justice officials and judges for whittling away basic rights.  The Hong Kong Sanctions Act requires the president to determine whether certain Hong Kong officials violated human rights and sanctions should be imposed in accordance with the Global Magnitsky Human Rights Accountability Act, the Hong Kong Human Rights and Democracy Act of 2019, or the Hong Kong Autonomy Act.  

Treasury’s Office of Foreign Assets Control (OFAC) announced sanctions on a sweeping roster of individuals and entities from People’s Republic of China (PRC), Türkiye, and the United Arab Emirates (the UAE) abetting Russia’s war against Ukraine by providing Russia with technology and equipment from third countries. The U.S. Department of State is also issuing nearly 100 sanctions today targeting Russia’s future energy production and revenue, metals and mining sector, defense procurement, and those involved in supporting the Russian government’s war effort and other malign activities.

In a coordinated effort with Canada and the UK, Treasury’s Office of Foreign Assets Control (OFAC) published a new directive that prohibits certain financial services by U.S. persons to or for the benefit of Myanma Oil and Gas Enterprise (MOGE), as well as five military regime appointed officials and officers.

  The Federal government announced the filing of a civil forfeiture complaint against the Motor Yacht Amadea, a 348-foot luxury vessel reportedly worth over $300 million.   The Complaint alleges that the superyacht, which is beneficially owned by Russian oligarch Suleiman Kerimov, was improved and maintained in violation of applicable sanctions against Kerimov and those acting on his behalf.

Two House bills seek to enforce sanctions on Iranian petroleum transactions.

Office of Foreign Assets Control (OFAC) is designating two individuals and four entities that form a core part of Specially Designated National (SDN) and Republika Srpska (RS) President Milorad Dodik’s patronage network. Members of this network, which include Dodik’s adult children, facilitate Dodik’s ongoing corruption in Bosnia and Herzegovina’s (BiH) RS entity, allowing him to siphon public funds from the RS and enrich himself and his family at the expense of BiH citizens and functional governance in the country.

In response to the signing of an electoral roadmap agreement between Venezuela’s Unitary Platform and representatives of Maduro,  Treasury’s Office of Foreign Assets Control (OFAC) issued 4 General Licenses suspending select sanctions.  The G/Ls permit limited trading in Oil, Gold and certain Venezuelan sovereign bonds and PdVSA debt and equity.

In a move aimed at curbing Iran's ballistic missile and unmanned aerial vehicle (UAV) programs, the U.S. Treasury's Office of Foreign Assets Control (OFAC) has imposed sanctions on 11 individuals, eight entities, and one vessel spread across Iran, Hong Kong, the People's Republic of China (PRC), and Venezuela. These entities have allegedly supported Iran's Islamic Revolutionary Guard Corps (IRGC), Ministry of Defense and Armed Forces Logistics (MODAFL), or their subordinates in the development and proliferation of missiles and UAVs.

The Price Cap Coalition released a Maritime Safety Advisory, emphasizing responsible trading in the maritime oil industry and compliance with the price caps. The Advisory, which is directed at both government and private sector actors involved in the maritime trade of crude oil and refined petroleum products, provides recommendations concerning specific best practices and reflects our commitment to promoting responsible practices in the industry, preventing and disrupting sanctioned trade, and enhancing compliance with the price cap. 

The Treasury Department announced it has imposed sanctions on seven individuals and four entities based in Iran, the People’s Republic of China, Russia and Türkiye in connection with Iran’s unmanned aerial vehicle and military aircraft development.

Treasury's Office of Foreign Assets Control sanctioned two commercial entities related to the conflict in Sudan, as well as five entities and two individuals involved in the procurement of sensitive parts for Iran’s one-way attack unmanned aerial vehicle (UAV) program. Elsewhere, OFAC sanctioned several Sinaloa Cartel affiliates and fugitives affiliated with Mexico’s Sinaloa Cartel. Responsible for a significant portion of the illicit fentanyl and other deadly drugs trafficked into the United States, the Sinaloa Cartel is one of the world’s most damaging transnational criminal organizations. Additionally, OFAC sanctioned the leader of the Clan del Golfo, one of Colombia’s largest criminal enterprises that controls most of the country’s cocaine cultivation, production, and transportation routes.

As a follow-up to the establishment of the “Export Enforcement Five” or “E5” partnership to coordinate on export control enforcement issues in June 2023, the governments of Australia, Canada, New Zealand, the United Kingdom, and the United States have issued joint guidance to industry and academia identifying high priority items critical to Russian weapons systems and urging specific actions to prevent diversion of these items to Russia through third countries.

The Commerce Department’s Bureau of Industry and Security (BIS) added 28 entities to its Entity List Monday, 24 September. The entities include 11 in China, 5 in Russia, 5 in Pakistan, and others in Finland, Oman, Germany, and the UAE. They have been implicated in activities threatening U.S. national security or foreign policy.

On July 3, 2023, the Office of Foreign Assets Control (OFAC) issued a recent actions notice, reminding holders of property blocked pursuant to OFAC sanctions regulations published in Chapter V of Title 31 of the Code of Federal Regulations (C.F.R.) of the requirement to provide OFAC with an Annual Report of Blocked Property (ARBP).  

3M has agreed to settle its potential civil liability for 54 apparent violations of OFAC sanctions on Iran that arose from its subsidiary’s sale of reflective license plate sheeting to an Iranian entity controlled by the Iranian Law Enforcement Forces. OFAC determined that these apparent violations were egregious and were voluntarily self-disclosed, and imposed a $9,618,477 settlement

U.S. government announced the establishment of a humanitarian channel in Qatar (HC) to further facilitate the flow of humanitarian assistance to the people of Iran consistent with the U.S. government’s longstanding support for humanitarian trade. Similar to humanitarian channels established under previous administrations, the HC is designed to support the Iranian people’s access to food, agricultural goods, medicine, and medical devices under stringent due diligence measures that guard against money laundering, misuse, and evasion of U.S. sanctions

Treasury’s Office of Foreign Assets Control (OFAC), in coordination with the Drug Enforcement Administration, designated key Hizballah operatives and financial facilitators in South America and Lebanon. This action includes the senior Hizballah operative, who carried out the terrorist attack against the Asociacion Mutual Israelita Argentina (AMIA) in Argentina in 1994 that killed 85 people. Amer Mohamed Akil Rada and his associates manage a commercial enterprise for Hizballah, including charcoal exports to Lebanon.

Treasury’s Office of Foreign Assets Control (OFAC) is designating 29 individuals and entities in connection with the Iranian regime’s violent suppression of nationwide protests following the death of Mahsa “Zhina” Amini in custody of its ‘Morality Police,’ and the regime’s continued efforts to detain dissenting voices and restrict access to a free and open internet. 

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