Sanctions

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.

Treasury’s Office of Foreign Assets Control is sanctioning over one dozen entities, individuals, and vessels that have played a central role in facilitating and financing the clandestine sale …

Tuesday the Treasury Department announced sanctions on Iranian cyber actors and representatives of Islamist extremists responsible for taking hostage U.S. nationals.

Treasury's Office of Foreign Assets Control (OFAC) announced a settlement with SCG Plastics Co., Ltd., part of a multinational enterprise headquartered in Bangkok, Thailand. SCG Plastics has agreed to pay $20,000,000 to settle its potential civil liability for 467 apparent violations of OFAC sanctions on Iran.

Treasury’s Office of Foreign Assets Control (OFAC) is taking sweeping actions against several actors involved in Iran’s unmanned aerial vehicle (UAV) program, suppliers and customers of one of Iran’s largest steel producers, and Iranian automobile companies with connections to U.S.-designated entities Islamic Revolutionary Guard Corps (IRGC) and the Ministry of Defense and Armed Forces Logistics (MODAFL).

The State Departemnt designated four entities pursuant to Executive Order 13382, which targets proliferators of weapons of mass destruction and their means of delivery. These entities – three based in the People’s Republic of China and one in Belarus – have supplied missile‐applicable items to Pakistan’s ballistic missile programs, including its long-range missile program.

In an effort to further isolate the Russian and Belarus military-industrial complex,  the U.S. Treasury’s Office of Foreign Assets Control (OFAC) is designating 12 entities and 10 individuals pursuant to Executive Order (E.O.) 14038,  The individuals and entities OFAC is targeting include six revenue-generating state-owned enterprises (SOEs) and one entity and five individuals involved in facilitating transactions for a U.S.-designated major Belarusian defense sector enterprise.

The Administration is calling on Congress to give it additional tools to prevent terrorist groups and other malign actors from using crypto-currencies to circumvent US sanctions. Treasury Deputy Secretary Wally Adeyemo told the Senate Banking Committee last week that the Administration needs “additional tools to protect the American people.”

In a joint action with UK officials, the Treasury Department issued two new prohibitions to disrupt the revenue that Russia earns from its export of aluminum, copper, and nickel.  This new action prohibits the import of Russian-origin aluminum, copper, and nickel into the US and UK, and limits the use of Russian-origin aluminum, copper, and nickel on global metal exchanges and in over-the-counter derivatives trading.

Commerce Department’s Bureau of Industry and Security (BIS) added 11 entities to the Entity List .Five of the eleven entities are Russian and PRC entities were added for actions related to unmanned aerial vehicles (UAVs). Of these, four are part of a procurement network for components for UAV applications. These components are used to develop and produce Shahed-series UAVs which have been used by Iran to attack oil tankers in the Middle East and by Russia in Ukraine.

Treasury’s Office of Foreign Assets Control (OFAC) is taking action against Hamas, targeting Gaza- and Lebanon-based leaders of the terrorist group’s offensive cyber and unmanned aerial vehicle (UAV) operations. Concurrent with this action, the European Union is imposing sanctions targeting Hamas. 

Friday the Council of the European Union adopted a law covering EU-wide minimum rules for the prosecution of violation or circumvention of EU sanctions in member states. Certain actions will now be considered criminal offences in all member states, for example helping to bypass a travel ban, trading in sanctioned goods or performing prohibited financial activities. Inciting, aiding and abetting these offences can also be penalised. 

Dronemaker General Atomics Aeronautical Systems and General Dynamics Land Systems, have been sanctioned by the Chinese government for their sales to the government of Taiwan.    Last September China sanctioned Northrop Grumman and Lockheed Martin  on the same grounds. Missing from either announcement was Boeing, Taipei’s supplier of Harpoon anti-ship missiles.

The Treasury Department announced it is targeting a network facilitating shipments valued in the hundreds of millions for the Iranian military. Treasury's Office of Foreign Assets Control announced additional action against Iranian military revenue generation, targeting Oceanlink Maritime DMCC for facilitating the shipment of Iranian commodities on behalf of Iran's Armed Forces General Staff and Ministry of Defense and Armed Forces Logistics.

Commerce's BIS extended the Temporary Denial Order for Russian air cargo operator Aviastar-TU initially imposed in April 2022. Aviastar has continued to engage in conduct prohibited by the TDO and Regulations, including, but not limited to, on flights into and out of Russia from/to Hangzhou, China as well as domestically within Russia. 

On March 26, the United States hosted the inaugural meeting of the U.S.-Republic of Korea (ROK) bilateral Enhanced Disruption Task Force (EDTF), which is being established to counter illicit efforts by the Democratic People’s Republic of Korea (DPRK) to circumvent sanctions concerning the procurement of refined petroleum.   Through EDTF, the United States and ROK are pursuing a wide range of joint actions to disrupt DPRK refined oil procurement networks, including by exposing DPRK sanctions evasion activities, reviewing options for autonomous sanctions designations, and engaging private sector and third-party actors throughout the region who facilitate – either knowingly or unwittingly – the DPRK’s oil procurement networks.

Treasury’s Office of Foreign Assets Control (OFAC) is sanctioning six entities, one individual and two tankers that are based or registered in Liberia, India, Vietnam, Lebanon, and Kuwait that have engaged in facilitating commodity shipments and financial transactions for the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF), the Houthis, and Hizballah.

Treasury’s Office of Foreign Assets Control (OFAC) sanctioned 11 individuals and entities supporting the regime of Syrian President Bashar Al-Assad through the facilitation of illicit financial transfers and trafficking of illegal drugs, as well as the extraction and export of Syrian commodities.  

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