Sanctions

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.

Treasury’s Office of Foreign Assets Control (OFAC) designated one Russian individual and three Russia-based companies involved in an attempted sanctions evasion scheme in which an "opaque and complex supposed divestment" could have unfrozen more than $1.5 billion worth of shares belonging to U.S.-designated Russian oligarch Oleg Deripaska. The transactions was part of a scheme to repatriate some of Austria's  Raiffeisen Bank capital stranded in Russia.

The Commerce Department’s Bureau of Industry and Security added 37 entities – mostly based in China – to the Entity List under the Export Administration Regulations.  BIS said the action, announced Thursday, reflects the Administration’s commitment to safeguarding US national security and foreign policy interests.

Etablissements Maurel & Prom S.A. (Paris:MAU) (“M&P”, “the Group”) announces it has received a specific license it had applied for on 1 September 2023 from the U.S. …

On Wednesday 8 May 2024, the UK government hosted a senior US government delegation for the second US-UK Strategic Sanctions Dialogue. The United States and the United Kingdom reaffirmed that sanctions and export controls are essential tools of national security policy. The delegations discussed the uses of targeted, coordinated sanctions and export control measures to deter and disrupt malign activity and to defend international norms.

OFAC has extended the General License 8M issued last November through November 2024. The GL authorizes certain disbursements necessary for the maintenance and security of operations, but not the drilling, lifting or transportation of petroleum for PDVSA, the Venezuelan state-owned oil company.

OFAC announced it has removed Russo-Maltese executive jet operator Emperor Aviation and its fleet from the list of Specially Designated Nationals.   No explanation was provided for the change. The company and aircraft had been added to OFAC’s Specially Designated Nationals (SDN) list for conducting travel for the family of Suleiman Kerimov.

OFAC has deployed its new Sanctions List Service (SLS).  SLS is now the primary application OFAC will use to deliver sanctions list files and data to the public. OFAC's Sanctions List …

May 1 the Treasury Department issued sanctions targeting Russia’s military-industrial base and chemical and biological weapons programs,  as well as companies and individuals in third countries that help Russia acquire key inputs for weapons or defense-related production. The action includes nearly 60 targets located in Azerbaijan, Belgium, the PRC, Russia, Slovakia, Türkiye, and the United Arab Emirates (UAE).  

On 1 May, the U.K. Office of Financial Sanctions Implementation (OFSI) introduced Frequently Asked Questions (FAQs), a new form of additional guidance aimed at providing technical support to industry partners and the public. 

Included among the munitions and TikTok drama, the foreign aid package signed last week has material changes for the sanctions compliance practitioner. Front and center for sanctions practitioners is the extension of the statute of limitations for sanctions (SOL) violations.

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