New sanctions on the Russian Central Bank, Ministry of Finance and two Russian investment funds announced Feb. 28 are the “most significant action” the Treasury Department has ever taken against an economy the size of Russia, said a senior administration official that day. “We're doing exactly what we said we’d do,” the official said during a call with reporters. “We said all options are on the table, including the most severe sanctions ever contemplated against Russia.”
OFAC
The Treasury Department's Office of Foreign Assets Control (OFAC) administers and enforces various economic and trade sanctions programs. It sanctions people and entities by adding them to the Specially Designated Nationals List, and it maintains several other restricted party lists, including the Non-SDN Chinese Military-Industrial Complex Companies List, which includes entities subject to certain investment restrictions.
The U.S. is imposing additional sanctions and new export controls following Russia's "further invasion of Ukraine," as promised by President Biden in his Feb. 22 speech (see 2202220003). The sanctions cover financial restrictions on Russian state-owned enterprises, banks, and individuals, while the export controls set restrictions on a variety of high-tech products. The new measures are part of an "unprecedented level of multilateral cooperation" according to the White House.
Akin Gump broadened its international trade practice with the addition of two former U.S. government officials and sanctions and export controls lawyers, the firm announced. Elyse Martin, former official at the Treasury Department's Office of Foreign Assets Control, and George Pence, former assistant U.S. attorney in the Central District of California, have joined the firm as senior counsel. While at OFAC, Martin served as the assistant director for Regulatory Affairs for two years and for over a year as chief of sanctions program implementation in the Sanctions Compliance and Evaluation Division, the firm said. As assistant U.S. attorney, Pence worked on investigations and prosecutions pertaining to export crimes, terrorism and other national security matters, it said.
The U.S. on Jan. 12 sanctioned seven people and one entity for helping to procure goods for North Korea’s weapons and missile programs. The Office of Foreign Assets Control sanctioned Russia-based North Korean national Choe Myong Hyon and four China-based North Korean weapons procurement officials: Sim Kwang Sok, Kim Song Hun, Kang Chol Hak and Pyon Kwang Chol. The State Department sanctioned North Korean national O Yong Ho, Russian national Roman Anatolyevich Alar and Russian entity Parsek LLC for helping to deliver weapons materials to North Korea. OFAC said the sanctions follow North Korea’s six missile launches since September, which violated U.N. Security Council resolutions.
The U.S. and the EU this week announced a coordinated set of sanctions against Nicaragua for the country’s “fraudulent” presidential elections that have kept the Daniel Ortega regime in power. The Office of Foreign Assets Control sanctioned six Nicaraguan government and military officials, and the EU sanctioned seven officials and three government entities. The U.S. and the EU announced the sanctions Jan. 10.
The Office of Foreign Assets Control imposed investment restrictions on SenseTime Group Ltd., a major Chinese technology company, and sanctioned 15 people and 10 other companies for human rights abuses, the agency said Dec. 10. SenseTime, which had prepared to price shares Dec. 10 in its initial public offering in Hong Kong, will now be subject to a U.S. investment ban and added to OFAC’s list of companies with ties to China’s military (see 2106030067).
The Office of Foreign Assets Control sanctioned people and entities in Uganda, Iran and Syria for human rights abuses or for undermining democratic institutions. The designations target military or government officials in all three countries as well as two Iranian law enforcement agencies and two Iranian prisons, OFAC said Dec. 7. The U.S. purposefully issued the sanctions just ahead of its democracy summit later this week, which will convene more than 100 of the world’s democracies to discuss collaboration on human rights issues, anti-corruption and more. “Consistent with the goals of this week’s Summit for Democracy, the United States is committed to using its full range of tools to counter serious human rights abuse and repressive acts across the world,” Secretary of State Antony Blinken said.
The Office of Foreign Assets Control this week sanctioned an additional 20 people, 12 entities and three aircraft for aiding the Alexander Lukashenko regime in Belarus. The agency also imposed new restrictions on dealings in Belarusian sovereign debt, and issued a new general license and 10 new frequently asked questions to provide guidance on the new sanctions.
The Office of Foreign Assets Control last week sanctioned six Iranians and one Iranian entity for trying to influence the 2020 U.S. presidential election. OFAC said they “sought to sow discord and undermine voters’ faith in the U.S. electoral process” through misinformation on social media, “threatening emails” and a video implying that “individuals could cast fraudulent ballots.” The designations targeted the Iranian cyber company Emennet Pasargad, its manager Mohammad Bagher Shirinkar and others affiliated with the company: Seyyed Mohammad Hosein Musa Kazemi, Sajjad Kashian, Mostafa Sarmadi, Seyyed Mehdi Hashemi Toghroljerdi and Hosein Akbari Nodeh. OFAC said it previously designated Shirinkar for supporting the Iranian military and previously sanctioned Emennet Pasargad under its former name: Net Peygard Samavat Co.
The U.S. and more than 30 other countries are meeting virtually this week to discuss how to better counter and disrupt ransomware attacks, including through sanctions, the White House said Oct. 13. The meetings come less than a month after the U.S. sanctioned SUEX, a large virtual currency exchange, for helping to facilitate transactions related to illegal ransomware attacks (see 2109210031). The White House said the Treasury Department “will continue to disrupt and hold accountable these ransomware actors and their money laundering networks,” and the meetings this week could be a forum for discussing multilateral actions.