Sanctions

U.S. Senator Marco Rubio (R-FL) introduced the Sanctions Recovery Act to "incentivize" OFAC to strictly enforce sanctions. "OFAC has not been as aggressive in sanctions enforcement as it should be." The bill would allow the agency to acquire 5 percent of foreign assets seized as well as of sanctioned fines. The amount collected would benefit salaries and administrative costs, and thus allow OFAC to increase sanctions and recompense Treasury for further enforcement efforts.

OFAC is amending and reissuing the Global Magnitsky Sanctions Regulations (31 CFR part 583) as a more comprehensive set of regulations that includes additional interpretive guidance and definitions, general licenses, and other regulatory provisions that will provide further guidance to the public. Further, OFAC is adding the Uyghur Human Rights Policy Act of 2020, as amended to the authority citation of 31 CFR part 583. Due to the number of regulatory sections being updated or added, OFAC is reissuing the Regulations in their entirety.

Treasury’s Office of Foreign Assets Control (OFAC) took additional action to target shipments of Iranian commodities undertaken by the network of Iran-based, Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF)-backed Houthi financial facilitator Sa’id al-Jamal. The most recent action targets two Hong Kong- and Marshall Islands-based ship owners and two vessels for their role in shipping commodities on behalf of al-Jamal, and follows a February 27 action targeting a related vessel, the ARTURA. 

Treasury’s Office of Foreign Assets Control (OFAC) designated two individuals and five entities associated with the Intellexa Consortium for their role in developing, operating, and distributing commercial spyware technology used to target Americans, including U.S. government officials, journalists, and policy experts. Since its founding in 2019, the Intellexa Consortium has acted as a marketing label for a variety of offensive cyber companies that offer commercial spyware and surveillance tools to enable targeted and mass surveillance campaigns.

Treasury is designating three entities and eleven individuals, including President Emmerson Mnangagwa, Vice President Constantino Chiwenga, Brigadier General (Retired) Walter Tapfumaneyi, and …

Treasury’s Office of Foreign Assets Control (OFAC) sanctioned two companies - one in Russia and one in the Central African Republic (CAR) - for their efforts in advancing Russia’s malign …

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) is issuing an OFAC Compliance Communiqué: Guidance for the Provision of Humanitarian-Related Assistance and Critical Commodities to the Yemeni People in response to questions from the NGO community and the general public on how to ensure humanitarian assistance and trade continue to flow to the Yemeni people while complying with OFAC sanctions. OFAC is also issuing Counter Terrorism General License 28, "Authorizing Transactions for Third-Country Diplomatic and Consular Missions Involving Ansarallah."  Ansarallah was added to the Specially Designated Nationals List.

The Departments of Justice, Commerce, and Treasury’s Office of Foreign Assets Control, have issued a Tri-Seal Compliance Note: Obligations of foreign-based persons to comply with U.S. sanctions and export control laws. The Note highlights the applicability of U.S. sanctions and export control laws to persons and entities located abroad, as well as the enforcement mechanisms that are available for the U.S. government to hold non-U.S. persons accountable for violations of such laws, including criminal prosecution.

Treasury's Office of Foreign Asset Control issued notices renaming and modifying sanctions in Sudan, updating Venezuela FAQs, and making grammatical changes to update existing sanctions.

Treasury’s Office of Foreign Assets Control (OFAC), in coordination with the United Kingdom, has sanctioned the Deputy Commander of Iran’s Islamic Revolutionary Guard Corps-Qods Force, a Yemeni militant, and two cargo vessels carrying Iranian petroleum.

Treasury’s Office of Foreign Assets Control (OFAC) has targeted Joint Stock Company Sovcomflot, Russia’s state-owned shipping company and fleet operator. In addition to designating Sovcomflot, OFAC is identifying 14 crude oil tankers as property in which Sovcomflot has an interest.

The Oil Price Cap permits service providers in Coalition countries to support the Russian oil trade only if the oil was sold at or below a specific cap. A Treasury policy note looks at the difference that the price cap is continuing to make three months into the second phase, as the coalition continues to take action to enforce the prohibition against the use of G7 services outside the cap.

Joining British and European allies, the US imposed a further raft of sanctions on Russia and her enablers. Treasury’s Office of Foreign Assets Control (OFAC) is sanctioning almost 300 individuals and entities. This is the largest number of sanctions imposed since Russia’s 2022 invasion of Ukraine. State is designating three Government of Russia officials in connection with Aleksey Navalny’s death; together, Treasury and State are sanctioning over 500 targets. The Department of Commerce is also adding more than 90 companies to the Entity List.

The European Union announced another round of sanctions on Russia and her allies, extending the reach to include Chinese and Indian firms complicit in avoiding existing restrictions.  The new measures focus on the procurement network supporting Russia's military, especially the supply chain to make drones. Twenty-seven companies were added to the Annex IV list, which means European firms cannot sell dual-use goods to them.

Representatives of the U.S. Departments of State, Commerce, and Treasury, along with delegations from the UK and Ukraine, joined senior EU and member state government officials for a Sanctions Coordinators Forum in Brussels Tuesday. "We reaffirmed our shared commitment to supporting Ukraine’s sovereignty and opposing Russia’s aggression and that sanctions are a key tool in that effort. The delegations discussed the use of targeted sanctions to deter and disrupt malign Russian activity and to demonstrate our readiness to take action to defend international norms," according to a State Department readout. The EU Statement was more comprehensive:

The Department of the Treasury's Office of Foreign Assets Control (OFAC) is amending the North Korea Sanctions Regulations to amend or add general licenses to facilitate certain humanitarian-related and journalistic activities. These changes include: additional non-governmental organization (NGO) activities, removal of dual licensing burden, expansion of authorization for the exportation or reexportation of certain food, medicine, and other agricultural and medical items, and a new G/L for Journalists.

Treasury’s Office of Foreign Assets Control (OFAC) sanctioned a procurement network responsible for facilitating the illegal export of goods and technology from over two dozen U.S. companies to end-users in Iran, including the Central Bank of Iran (CBI), which is designated for its role in providing financial support to the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) and Hizballah. Among sanctioned firms are an Iranian subsidiary of Iran’s Central Bank that most recently developed the Central Bank Digital Currency platform for the bank; a UAE-based front company, which acquired U.S. tech for the Central Bank of Iran and the front company’s CEO, as well as a Turkey-based affiliate firm that also made purchases that ended up in Iran.

Treasury’s Office of Foreign Assets Control (OFAC) has taken its second price cap enforcement action of 2024, imposing sanctions on four entities and identifying one vessel as blocked property. OFAC is also issuing two new determinations that implement G7 commitments to ban the importation of Russian diamonds.

The Justice Department announced the unsealing of three federal cases, across two U.S. Attorneys’ Offices, as the most recent in a series of efforts to combat the illicit trafficking of Iranian oil that funds Iran’s Islamic Revolutionary Guard Corps (IRGC), and its Qods Force (IRGC-QF), Iran’s primary mechanism for cultivating and providing lethal support to terrorist organizations abroad Seven defendants are charged in the Southern district of New York, along with the seizure of $108 million. Two more defendants were named in a case filed in the District of Columbia, along with a forfeiture complaint for 500,000 barrels of oil in transit.

The Department of Defense released an updated blacklist with more than a dozen new Chinese companies on it, including memory chip maker YMTC, artificial intelligence company Megvii, LiDAR maker Hesai Technology and tech company NetPosa.   Section 1260H of the William M. (Mac) Thornberry NDAA for FY21 (Pub. L. 116–283) directs the Secretary of Defense to continue to list “Chinese military companies” (CMCs) annually until December 31, 2030.

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