Sanctions

Treasury’s Office of Foreign Assets Control (OFAC) is sanctioning ten individuals, entities, and vessels, including tanker captains, in multiple jurisdictions that have engaged in the illicit transport of oil and other commodities, including for the network of Houthi financial facilitator Sa’id al-Jamal. This action targets maritime shipping and financial facilitators, several vessel managers and owners, and a company involved in forging shipping documents.

Treasury’s Office of Foreign Assets Control (OFAC) sanctioned members of one of Guyana’s wealthiest families, Nazar Mohamed and his son, Azruddin Mohamed, their company, Mohamed’s Enterprise, and a Guyanese government official, Mae Thomas , for their roles in public corruption in Guyana. Azruddin and Mohamed’s Enterprise evaded Guyana’s tax on gold exports and defrauded the Guyanese government of tax revenues by under­declaring their gold exports to Guyanese authorities. Between 2019 and 2023, Mohamed’s Enterprise omitted more than 10 thousand kilograms of gold from import and export declarations and avoided paying more than $50 million in duty taxes to the Government of Guyana.

To support the Department's announcement of over 300 new sanctions Wednesday, Treasury's Office of Foreign Assets Control (OFAC) is publishing Determinations, General Licenses and FAQs relating to trade with Russia and Belarus

In coordination with the Departments of Treasury and State, the Commerce Department’s Bureau of Industry and Security (BIS) is announcing several significant additional export control restrictions and related actions against Russia.. Among the actions is the issuance of a final rule imposing additional export control measures against Russia and Belarus by expanding the scope of items identified under two EAR supplements that are subject to the EAR’s Russian and Belarusian industry sector sanctions; imposing a “software” license requirement for certain EAR99-designated “software” when destined to or within Russia or Belarus; and narrowing the scope of commodities and software that may be authorized for export, reexport, or transfer (in- country) to or within Russia or Belarus under License Exception Consumer Communications Devices (CCD).

The Treasury and State Departments are  issuing sweeping new measures guided by G7 commitments to intensify the pressure on Russia for its continued war against Ukraine. Wednesday's actions ratchet up the risk of secondary sanctions for foreign financial institutions that deal with Russia’s war economy; restrict the ability of Russian military-industrial base to take advantage of certain U.S. software and information technology (IT) services; and, together with the Department of State, target more than 300 individuals and entities.

Tim O’Toole of Miller & Chevalier sat down with Erich Ferrari of Ferrari & Associates  to discuss demystifying the OFAC delisting process, and avoiding thst sanction in the first place.

Treasury’s Office of Foreign Assets Control (OFAC) is materially amending the Syrian Sanctions Regulations, 31 C.F.R. Part 542. In addition to new prohibitions, OFAC is adding several relevant definitions and interpretations and one new general license.  OFAC is also incorporating, with amendments, one general license; updating six general licenses; and publishing a list of areas in which activities are authorized under General License 22.

The Department of State is publicly designating five current and former Ugandan officials for their involvement in significant corruption or gross violations of human rights. Included in the action are the Speaker of Parliament, Former Minister of Karamoja Affairs, former Minister of State for Karamoja Affairs, and the Minister of State for Finance. Additionally, the former Deputy Chief of the Ugandan Peoples’ Defence Forces is designated due to his involvement in gross violations of human rights

Treasury’s Office of Foreign Assets Control (OFAC) sanctioned two companies that are linked to the Private Military Company “Wagner” (Wagner Group). Mining Industries SARLU and Logistique Economique Etrangere SARLU are being designated pursuant to Executive Order (E.O.) 14024 for enabling Wagner Group security operations and Wagner Group-linked illicit mining endeavors in the Central African Republic (CAR).

The US Treasury is targeting four entities associated with OFAC-designated Rayan Roshd Afzar Company (RRA) that have procured critical parts for Iran’s unmanned aerial vehicle (UAV) program. Additionally, OFAC is targeting an Iranian executive of Iran Aviation Industries Organization (IAIO), a subsidiary of Iran’s Ministry of Defense and Armed Forces Logistics that oversees UAV manufacturers Iran Aircraft Manufacturing Industrial Company and Qods Aviation Industries.

Twelve GOP lawmakers sent a letter to U.S. Treasury Secretary Janet Yellen calling on the Office of Foreign Assets Control and Financial Crimes Enforcement Network to investigate six People's Republic of China (PRC) companies, including two of the largest oil companies in the PRC. .The apparent intent is to discourage US investors from owning shares in the firms, several of which are included in East Asian Stock Indexes.

Treasury's Office of Foreign Assets Control (OFAC) is amending the Cuban Assets Control Regulations (the “Regulations”) to further implement elements of the policy announced by the Administration on May 16, 2022, Cuban entrepreneurs' access to internet-based services and banking facilities are improved, while the restrictions on transactions with state-owned entities remain fully in force.

A bipartisan group of lawmakers are urging President Biden to act on a new law allowing him to seize frozen Russian assets and give them to Ukraine for reconstruction ahead of the G7 finance ministers’ meeting. The lawmakers asked for a briefing by June 1 on the progress of talks being led by the National Security Council to encourage G7 and European Union partners to find creative mechanisms for using Russian sovereign funds frozen in their respective jurisdictions.

Treasury Secretary Janet Yellen convened with German bankers on Tuesday. The roundtable discussion focused on global macroeconomic trends, the risks to financial security, and the impact of multilateral sanctions against Russia. She asked bankers to be more proactive in their adherence to sanctions restrictions, and to impress the same upon their affiliates and correspondents. In remarks to the Frankfurt School of Finance and Management the day prior, Yellen defended the Boden Administrations efforts to rebuild the transatlantic alliance. "Put simply, the transatlantic alliance has delivered for Americans, Europeans, and many others. And the United States has been committed to advancing it—through multilateralism, most notably through the G7, NATO, and U.S. relations with the EU—and through bilateral relationships between the U.S. and European countries, including, of course, with Germany.

After deftly avoiding the sanctions levied in the past on US Defense contractors by Beijing for their transactions with Taipei,  Boeing’s Defense, Space & Security unit has been placed on the Ministry of Commerce's “unreliable entities list" (UEL). In April MofCom sanctioned dronemaker General Atomics and General Dynamics Land Systems, while the announcement omitted Boeing, the maker of Taipei's Harpoon anti-ship misssile system.  The May 20 announcement reiterates the April actions, adding Boeing.

The termination of general license 44A, which had offered temporary relief from Venezuel oil sanctions, reportedly has created a crush of license applications to OFAC.

In response to Ankara's suspension of trade with Israel,The US Department of Commerce's Bureau of Industry and Security (BIS) has issued an antiboycott advisory on Turkey. U.S. companies operating in Türkiye, in particular, are cautioned to be alert to their receipt of any requests to refrain from importing or exporting goods to or from Israel or to provide certification that the goods are not of Israeli origin or do not contain Israeli-origin components or materials. 

Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Ali Yagoub Gibril and Osman Mohamed Hamid Mohamed, pursuant to Executive Order (E.O.) 14098, for leading the Rapid Support Forces’ (RSF) war campaign. The RSF’s attacks in North Darfur, which started last month, have caused dozens of civilian casualties, including children.

Treasury’s Office of Foreign Assets Control (OFAC) is imposing sanctions on two Russian individuals and three Russia-based entities for facilitating weapons transfers between Russia and the Democratic People’s Republic of Korea (DPRK).

Treasury is imposing sanctions on three Nicaragua-based entities, the Training Center of the Russian Ministry of Internal Affairs in Managua (RTC); Compania Minera Internacional, S.A. (COMINTSA); and Capital Mining Investment Nicaragua, S.A. The RTC is a Nicaragua-based subdivision of the Government of the Russian Federation’s (GOR) Ministry of Internal Affairs, and is a "key actor in the Nicaraguan regime’s repression of civil society and unjust detention and imprisonment of individuals for expressing dissent, or otherwise peacefully exercising their human rights and fundamental freedoms," according to the OFAC statement. The designations of COMINTSA and Capital Mining target government-affiliated gold companies generating revenue for the Ortega-Murillo regime. Gold is Nicaragua’s top commodity export.

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