On January 17, 2024, the US Department of the Treasury (“Treasury”) Office of Foreign Assets Control (“OFAC”) announced the re-addition of Ansarallah, better known as the Houthis, to the List of Specially Designated Nationals and Blocked Persons (“SDN List”) as a Specially Designated Global Terrorist, just shy of three years after delisting the group to
Sanctions
OFAC Updates Civil Monetary Penalties
Last week, OFAC announced it is increasing its maximum amount of the civil monetary penalties (CMP) that may be assessed under relevant OFAC regulations by implementing the Federal Civil Penalties Inflation Adjustment Act of 1990 for 2024. These increases adjust for inflation and have occurred nine times since 2015. The changes to the CMPs are…
Treasury’s OFAC Announces Magnitsky Designations for Two Former Afghan Government Officials
On December 11, the U.S. Department of Treasury (“Treasury”)’s Office of Foreign Assets Control (“OFAC”) announced sanctions against two former Afghan government officials, Mir Rahman Rahmani and his son, Ajmal Rahmani (collectively, “the Rahmanis”), as well as 44 associated entities. These individuals and entities were designated pursuant to Executive Order 13818, which builds upon and…
EU Considers Adding More Teeth to Sanctions Enforcement with Adoption of Draft Law Criminalizing Sanctions Evasion
Key Takeaways
Joint Agency Guidance to Exporters on Iran’s UAV Activities
Last Friday, the U.S. Departments of Commerce, Justice, State, and the Treasury issued a joint guidance sheet on Iran’s unmanned aerial vehicles (“UAVs”) program (the “Iran UAV Guidance”). The Iran UAV Guidance highlighted (I) the threat Iran’s UAV program poses; (II) the key items that Iran relies on to expand its UAV program; (III) the…
Sanctions/Export Highlights [As of October 6, 2022]
New U.S., UK, and EU Designations: On September 30, 2022, the U.S. designated 295 individuals and entities. The new designations included 14 persons in Russia’s military industrial complex, including Sinno Electronics Co. and Taco LLC, Chinese and Armenian suppliers, for their support of a Russian defense procurement firm. The U.S. also targeted two Russian…
Sanctions/Export Highlights [As of September 22, 2022]
UK Amends Designation of Arkady Rotenberg: On September 16, 2022, the UK replaced the designation entry for Arkady Romanovich Rotenberg. The new entry description focuses on Mr. Rotenberg’s role in the construction of the Kerch Bridge, and the railway line on the bridge, which stretch from Russia to Crimea. Mr. Rotenberg was originally designated…
Sanctions/Export Highlights [As of August 18, 2022]
UK Publishes General License for Energy for Mongolia: On August 16, 2022, the UK published General License INT/2022/2085212 for Mongolia energy payments. The license permits payments to the Credit Bank of Moscow, Gazprombank, Sberbank, Rosbank PJSC, or any entity owned or controlled by these banks, for the purpose of making energy available for use…
Treasury Sanctions Tornado Cash and Turns Up Heat on Mixers
On August 8, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) sanctioned virtual currency mixing service Tornado Cash, which OFAC said has been used to launder billions of dollars in virtual currency, including $455 million stolen by the Lazarus Group, a Democratic People’s Republic of Korea (“DPRK”) state-sponsored hacking group…
Sanctions/Export Highlights [As of May 6, 2022]
Russia Sanctions: The UK designated 63 individuals this week, including several war correspondents embedded with Russian forces in Ukraine that work at Channel One, a major state-owned media outlet in Russia. The UK also designated one entity, Evraz PLC, a UK-incorporated holding company of a multinational steel manufacturing and mining company group. Additionally, the…