A financial software company recently disclosed to the Office of Foreign Assets Control that it may have violated U.S. sanctions by allowing its services to be used by customers in restricted countries.
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. issued nearly 400 new financial blocking sanctions last week against people and companies in Russia and across Asia, Europe and the Middle East for aiding Russia’s war effort against Ukraine. The designations, issued by the Treasury and State departments, target “numerous” Russia-related procurement and sanctions evasion networks along with businesses involved in the Russian energy and mining industries, supporting the country’s military industrial base, connected to Russian state-owned entities, helping to forcibly re-educate Ukrainian children and more.
The U.S., the U.K. and Canada last week issued new, coordinated sanctions against Belarus, targeting people, companies and entities that are helping Russia evade sanctions and export controls, funding Belarusian oligarchs tied to President Alexander Lukashenko or taking other steps to aid the Russian or Belarusian governments. The sanctions, which were announced days after a similar set of designations imposed by the EU (see 2408050008), were meant to mark the four-year anniversary of the “fraudulent” 2020 presidential election that helped Lukashenko keep power, the countries said in a joint statement.
The U.S. Supreme Court's decision in Loper Bright v. Raimondo rejecting the Chevron principle of deferring to federal agencies' interpretations of ambiguous statutes doesn't call for the U.S. District Court for the District of Columbia to revisit a decision sustaining the sanctions designation of former Afghan government official Mir Rahman Rahmani and his son, Hafi Ajmal Rahmani, the U.S. said this week (Mir Rahman Rahmani v. Janet Yellen, D.D.C. # 24-00285).
The Office of Foreign Assets Control this week sanctioned five people and seven entities across mainland China, Hong Kong and Iran for helping to provide key parts to Iran’s missile and drone programs. OFAC said they procure accelerometers, gyroscopes and other components that “serve as key inputs” for Iranian weapons programs, which that country uses to produce drones for Russia and its “proxies” in the Middle East.
The U.S. is considering “consequences,” including possibly sanctions actions, against Venezuela after the country’s Nicolas Maduro-led regime appeared to alter the results of the country’s presidential elections, senior administration officials said this week.
A Massachusetts financial services firm agreed to pay a nearly $7.5 million penalty after the Office of Foreign Assets Control accused its subsidiary of revising dates on invoices to skirt certain financial restrictions on dealings in new Russia-related debt. OFAC said the company’s 38 violations of the Ukraine-/Russia-Related Sanctions Regulations involved more than $1.2 million worth of invoices for companies owned by Russia’s Sberbank and VTB Bank.
The Office of Foreign Assets Control this week sanctioned a network of people and companies in China involved in procuring items for North Korea’s weapons programs, which the country is using to provide missiles to Russia’s military. OFAC said North Korea is relying on this Chinese network to buy foreign-sourced materials and parts that it can’t produce domestically. The companies “consolidate and repackage items for onward shipment” to North Korea, the agency said, and hide the “true end-user” from the manufacturers and distributors of those items.
The EU is considering entities to be subject to sanctions if they are owned 50% or more by another sanctioned entity or party, a move that aligns the bloc with the U.S. Office of Foreign Assets Control’s 50% rule. The announcement is a change from the EU’s previous position on the ownership test threshold, which had previously extended asset freezes to entities only if they were owned more than 50% by a sanctioned party, a law firm said this week.
The U.S., the U.K. and Australia this week sanctioned Russian national Dmitry Yuryevich Khoroshev, a leader of the Russia-based LockBit ransomware group, which the Office of Foreign Assets Control labeled “one of the most active ransomware groups in the world.”