Sanctions

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  …

  Treasury's Office of Foreign Assets Control (OFAC) is issuing Venezuela-related General License 8M, "Authorizing Transactions Involving Petróleos de Venezuela, S.A. (PdVSA) Necessary for the Limited Maintenance of Essential Operations in Venezuela or the Wind Down of Operations in Venezuela for Certain Entities," and Venezuela-related General License 45A, "Authorizing Certain Transactions Involving Consorcio Venezolano de Industrias Aeronáuticas y Servicios Aéreos, S.A."  Additionally, OFAC is publishing an updated, related document "Frequently Asked Questions Related to the Suspension of Certain U.S. Sanctions with Respect to Venezuela on October 18, 2023."

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 Assistance to the Palestinian People in response to questions from the NGO community and the general public on how to provide humanitarian assistance while complying with OFAC sanctions. Neither Gaza nor the West Bank are subject to jurisdiction-based sanctions or an embargo by OFAC.  Further, OFAC authorizes limited transactions with blocked persons to the extent such dealings are ordinarily incident and necessary to certain humanitarian activity,

The House Financial Services Committee passed 11 bills last week sanctioning Iran and Hamas, in response to the Tehran's role in funding Hamas militants responsible for the Oct. 7 attacks on Israel. Some bills sought to rein in the Biden administration's dealings with the Iranian regime. Others were meant to "ensure that any humanitarian assistance to Iran is not used to finance acts of terror," according to a press release from the committee. It remains to be seen if House Leadership has the discipline and motivation to bring the bills to a successful resolution in any measurable period of time.

House Foreign Affairs Committee Chairman Michael McCaul (R-Texas) wants to know the reasoning behind the Administration’s decision to lift sanctions on the Maduro regime in Venezuela. “The regime will enrich itself from this Administration’s sanctions relief while the Venezuelan people remain without a viable path for free and fair elections,” he wrote.

Britian's National Crime Agency has issued an alert warning that Russia is using gold as a means to undermine the impact of the UK sanctions regime. Given the importance of the UK to the gold market, the NCA is warning of deliberate attempts are being made to launder sanctioned gold to mask its origin so that it can be hidden in supply chains and sold in the UK and around the world.

President Biden has continued for one year the investment restrictions placed on Chinese securities associated with the PRC's Civil-Military Fusion (CMF) industrial policy. The restrictions include tradeing is securities of Chinese firms in the defense sector, as well as entities deemed controlled by the Chinese Communist Party.

The United States on November 3 placed sanctions on a Russian national for allegedly helping Russian elites launder and transfer money using virtual currency in contravention of sanctions …

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