Sanctions

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.

Treasury’s Office of Foreign Assets Control (OFAC) sanctioned over 20 individuals and entities for their involvement in financial facilitation networks for the benefit of Iran’s Ministry of Defense and Armed Forces Logistics and Iranian Armed Forces General Staff, and the Islamic Revolutionary Guard Corps-Qods Force.  

Treasury’s Office of Foreign Assets Control (OFAC) sanctioned three entities and blocked three vessels that used Price Cap Coalition services while carrying Russian crude oil above the Coalition-agreed price cap.   The vessels NS Champion, Viktor Bakaev, and HS Atlantica used U.S.-person services while carrying Russian Urals crude priced above $70 per barrel after the price cap took effect

The Treasury Department’s Office of Foreign Assets Control is imposing sanctions on three entities and identifying as blocked property three vessels that carried Russian crude oil above the price cap agreed to by the United States and its allies. “Shipping companies and vessels participating in the Russian oil trade while using Price Cap Coalition service providers should fully understand that we will hold them accountable for compliance,” Treasury Deputy Secretary Wally Adeyemo.

As Nicaraguan President Daniel Ortega continues his four decade devolution  from radical chic hero of the revolution to Somoza-style latin despot, the Biden Administration renewed the Trump-era  restrictions on travel and property ownership by Ortega and his cadre.

The  OFAC-OFSI Enhanced Partnership , UK Office of Financial Sanctions Implementation (OFSI) and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) marked  …

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