OFAC took significant sanctions action over the last week in the malicious cyber-enabled activities and North Korea programs, the Burma program, and the Congo program, as well as removing an individual from OFAC’s SDN List:
Malicious Cyber-Enabled Activities and North Korea-related Sanctions
- OFAC Sanctions Tornado Cash Founder: OFAC on Aug. 23 sanctioned Roman Semenov, one of three co-founders of the sanctioned virtual currency mixer Tornado Cash, for his role in providing material support to Tornado Cash and to the Lazarus Group, North Korea’s state-sponsored hacking group under both programs. Tornado Cash, created in 2019, and designated in 2022, was used to launder large amounts of funds for criminal actors, including to obfuscate hundreds of millions of dollars in virtual currency stolen by Lazarus Group hackers. Tornado Cash previously challenged this OFAC designation in federal court, and on Aug. 17, the designation was upheld in the Western District of Texas. OFAC’s action was coordinated with the U.S. Department of Justice which unsealed an indictment against Semenov charging him with conspiracies to launder over $1 billion in criminal proceeds and violate sanctions. A second co-founder of Tornado Cash, Roman Storm, was arrested on Aug. 23 by the Federal Bureau of Investigation and the Internal Revenue Service, Criminal Investigation. A third co-founder of Tornado Cash, Alexey Pertsev, was arrested on related money laundering charges in the Netherlands in August 2022 by Dutch law enforcement authorities. Read more.
Burma-related Sanctions
- OFAC Determines a New Sector in the Burma Program and Targets Specific Burmese Regime Jet Fuel Suppliers: OFAC, in response to the Burmese military regime’s violent airstrikes against the people of Burma, issued a determination that allows sanctions to be imposed on any foreign individual or entity that operates in the jet fuel sector of the Burmese economy. Concurrently, OFAC designated two individuals and one entity that are involved in the procurement and distribution of jet fuel to Burma’s military regime, and two entities for being owned or controlled by the designated persons. OFAC designated Khin Phyu Win, who is associated with multiple jet fuel related companies within the Asia Sun Group, which imported jet fuel on behalf of Burma’s military regime. OFAC also designated her companies Shoon Energy PTE. LTD., PEIA PTE. LTD., and P.E.I Energy PTE. LTD. A second individual, Zaw Min Tun, the director and owner of 11 Asia Sun Group companies was also designated by OFAC. Read more.
- Related to this action, OFAC issued Frequently Asked Questions 1132 and 1133. FAQ 1132 confirms that the sectoral designation does not target all persons that operate or have operated in the jet fuel sector of the Burmese economy, but rather permits OFAC to designate foreign persons operating in the “jet fuel sector of the Burmese economy.” FAQ 1133 explains OFAC’s interpretation of the term “jet fuel sector of the Burmese economy.”
Congo-related Sanctions
- OFAC Sanctions Individuals Contributing to Conflict and Instability in Congo: OFAC on Aug. 24 sanctioned six individuals for contributing to the recent escalation of conflict in the eastern Democratic Republic of the Congo. OFAC designated Apollinaire Hakizimana, Brigadier General Sebastian Uwimbabazi, Ruvugayimikore Protogene, Bernard Byamungu, Colonel Salomon Tokolonga and Brigadier General Andrew Nyamvumba. OFAC’s sanctions reflect the United States’ commitment to advancing efforts toward resolution of the crisis, promoting accountability for human rights abuses including conflict-related sexual violence, and addressing the dire humanitarian situation. Read more.
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