Sanctions

The United States Department of Justice announced the filing of a civil forfeiture complaint to seize over $3.4 million in proceeds from the sale of a Southern California music studio owned by Russian oligarch Oleg Deripaska. Mr. Deripaska acquired the Burbank music studio in 2008 through shell companies. After his 2018 designation as a Specially Designated National (SDN), Deripaska’s associates facilitated the sale of the studio and its contents, generating proceeds that were allegedly funneled through a series of transactions designed to evade sanctions.

The United States is imposing sanctions on 35 entities and vessels that play a critical role in transporting illicit Iranian petroleum to foreign markets. This action builds upon the sanctions issued …

Treasury’s Office of Foreign Assets Control (OFAC) has imposed sanctions on five individuals and four entities linked to the TGR Group, an international network facilitating sanctions evasion for Russian elites. The TGR Group, known for leveraging digital assets such as U.S. dollar-backed stablecoins, has been instrumental in circumventing U.S. and international sanctions.

The International Trade and Security group of Morgan Lewis brings to our attention the following: The Fifth Circuit Court of Appeals ruled that immutable smart contracts on Tornado Cash, a cryptocurrency transaction protocol, are not “property” under the jurisdiction of the Office of Foreign Assets Control (OFAC). This decision restricts OFAC’s ability to sanction Tornado Cash based on such contracts. The court relied on the Supreme Court’s Loper Bright Enterprises v. Raimondo decision, emphasizing that immutable smart contracts lack traditional characteristics of property, such as ownership and control.

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has sanctioned 21 Venezuelan officials, including security and cabinet-level leaders aligned with Nicolás Maduro. These actions, pursuant to Executive Order 13692, target individuals for supporting Maduro’s repression of civil society and attempts to declare himself the winner of the July 28 presidential election, despite Edmundo González Urrutia being elected by a significant majority.

Treasury’s Office of Foreign Assets Control (OFAC) has announced full blocking sanctions against 118 entities and individuals, including Gazprombank and fifty other banks. Thursday's actions bring it in alignment with allied sanctions on  Gazprombank—the largest bank not previously sanctioned. OFAC’s action includes the designation of Gazprombank, more than 50 internationally connected Russian banks, more than 40 Russian securities registrars, and 15 Russian finance officials.

Treasury’s Office of Foreign Assets Control (OFAC) has announced sanctions against 26 entities and individuals linked to the Syrian conglomerate Al-Qatirji Company. The company is involved in shipping Iranian oil to Syria and the People’s Republic of China,.

The Treasury reversed its denial of an application in 2022 to host small group, direct engagement conferences which include the participation of sanctioned individuals.

Treasury's Office of Foreign Assets Control (OFAC) is amending several Frequently Asked Questions (FAQs) today, as well as issuing two new FAQs related to payment of claims.

The Department of the Treasury’s Office of Foreign Assets Control (OFAC) has issued a final rule amending the Burma Sanctions Regulations to more fully implement the directives of Executive …

A change of regime in Washington may change the degree of sanctions pressure on Russian Arctic gas projects, though the ultimate decider remains the economics.   With the White House encouraging  production and exports of domestic LNG, the incentives to make it easier for the Moscow regime to sell their gas may not be that pronounced. Russia's Arctic LNG 2 project, spearheaded by Novatek, seeks to export nearly 20 million tons of liquefied natural gas annually to Europe and Asia. Strategically located on the Gydan Peninsula, it aims to leverage the Northern Sea Route to cut transit times. However, Western sanctions, particularly under the Biden administration, have constrained Russia’s ability to capitalize on its Arctic resources by limiting access to technology and financing.

 A Turkish National was arrested for his involvement in a complex scheme to violate and evade U.S. sanctions related to petroleum products from Venezuela and Iran.. The scheme included obfuscating the identities of tankers moving the oil by re-naming and re-flagging vessels, covering vessel names with paint or blankets, and turning off the electronics that track vessels’ locations for the safety of ships and their crews

OFAC imposied sanctions today on one entity and one individual that form part of Republika Srpska (RS) President Milorad Dodik’s patronage network.  The U.S. government previously designated President Dodik for using his official position to accumulate personal wealth through companies connected to himself and his son, Igor Dodik. 

OFAC is issuing an OFAC Compliance Communiqué: Sanctions Compliance Guidance for the Maritime Shipping Industry  This scenario-based guidance is to aid maritime sector stakeholders in identifying certain new or common fact patterns that may be indicative of sanctions evasion, addressing common counterparty due diligence issues, and implementing best practices to promote sanctions compliance

Citing a "blatant disregard of U.S. export controls and the TDO," the Bureau of Industry and Security has renewed the temporary denial order dating to 2008 on Iran's largest airline.   "The de facto airline of Iran’s Islamic Revolutionary Guard Corps (IRGC)," according to industry observers, Mahan operates a modern fleet of western aircraft supported by a network of subsidiary airlines and service companies in African and Asian countries such as Burkina Faso, Gambia, Indonesia, and Mali.

Included in Wednesday's sanctions package, OFAC designated two Swiss lawyers for creating companies and trusts to help Russian clients evade sanctions.   Andres Baumgartner and Fabio Libero Delco facilitated the illicit flow of funds while avoiding oversight due to a loophole in Swiss law that allows lawyers to serve as non-financial intermediaries under the guise of their profession without due diligence or reporting requirements. 

Ottawa the UK and the EU Tuesday  announced sanctions against 3 individuals and 4 entities for supplying weapons and military equipment to the Myanmar military. The sanctions announced respond to the ongoing and increasing aerial attacks by the Myanmar military regime. Over the last six months, military airstrikes killed almost 400 civilians, including more than 60 children, and injured more than 750 people.

The State Department, Commerce and the Treasury announced sweeping sanctions on nearly 400 individuals and entities across 17 jurisdictions involved in providing advanced technology, equipment, and financial support to Russia’s military-industrial complex.

The total amount of claims of 17 Russian TV channels to Google has reached 2 undecillion rubles, according to reporting by RBC . Undecillion is a unit with 36 zeros. Dating to a 2020 decision to block YouTube accounts controlled by parties subject to the 2014 US sanctions, Google's troubles compounded when it blocked Sputnik, RT and other state controlled channels in February 2022.

Executive Order 14114, issued by President Biden on December 22, 2023, amends E.O. 14068 to ban the importation of certain seafood and diamonds originating from the Russian Federation. The order mandates that the Department of Homeland Security (with the Treasury's concurrence) implement data collection for enforcing these prohibitions. Filed on: 10/21/2024 at 8:45 am Scheduled Pub. Date: 10/22/2024 FR Document: 2024-24341 PDF 9 Pages (126 KB) …

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