Guidance
- OFAC Issues Sanctions Compliance Guidance to Facilitate Providing Humanitarian Assistance to the Palestinian People: OFAC on Nov. 14 issued an OFAC Compliance Communiqué: Guidance for the Provision of Humanitarian Assistance to the Palestinian People in response to questions from the NGO community and the general public on how to provide humanitarian assistance while complying with OFAC sanctions. Read the guidance.
The Office of Foreign Assets Control took a number of significant sanctions actions over the last week across multiple programs:
Russia-related Sanctions
- OFAC Sanctions Maritime Companies, Vessels Transporting Oil Sold Above the Coalition Price Cap: In response to reports of Russian oil sales above the price cap determined by coalition partners, OFAC on Nov. 16 imposed sanctions on three entities and identified three vessels as blocked properties. The vessels used Price Cap Coalition service providers while carrying Russian crude oil above the Coalition-agreed price cap. OFAC identified the vessels Kazan, Ligovsky Prospect, and NS Century as vessels engaged in the export of Russian crude oil priced above $60 per barrel after the crude oil price cap took effect. The entities Kazan Shipping, Progress Shipping, and Gallion Navigation were designated pursuant to Executive Order 14024 for operating or having operated in the marine sector of the Russian economy. OFAC’s action underscores Treasury’s commitment, alongside its international partners, to responsibly reducing oil revenues that the Russian government can use to finance its invasion of Ukraine. Read more.
Balkans-related Sanctions
- OFAC Designates Individuals and Entities under the Western Balkans program: OFAC on Nov. 16 designated eight individuals and six entities pursuant to Western Balkans-related Executive Order 14033 and Russia-related E.O. 14024. In a coordinated action, the U.S. Department of State also designated two individuals and 12 entities pursuant to E.O. 14024. The designees include Bosnia and Herzegovina-based, Savo Cvijetinovic, a member of the executive board of Republika Srpska (RS) President Milorad Dodik’s political party; Petar Djokic, the current RS Minister of Industry, Energy, and Mining; Dusko Perovic, head of RS representational office in Moscow, Russia; Montenegro-based, Miodrag “Daka” Davidovic and Branislav “Brano” Micunovic; North Macedonia-based, Sergey Samsonenko and his wife, Irina Samsonenko, among others. The designees are involved in corruption, money laundering and for their roles in destabilizing the situation in the Western Balkans. The designated entities include Kamchev Konsalting Skopje DOOEL, Orka Fajnans Skopje DOOEL, Orka Holding AD, Sistina Lajf Kear Sentar Skopje DOOEL and Bet City International DOO Skopje. The designated entities are owned or controlled by the designees. Read more.
- In a related action, OFAC issued Russia-related General License 77, “Authorizing Limited Safety and Environmental Transactions Involving Certain Persons or Vessels”, Balkans-related General License 2, “Authorizing the Wind Down of Transactions Involving Orka Holding AD”, and Balkans-related General License 3, “Authorizing Certain Transactions Related to Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, Software Updates, or Medical Prevention, Diagnosis, or Treatment, or Clinical Trials Involving Orka Holding AD.” OFAC also issued a related Frequently Asked Question 1140 to answer if U.S. persons are authorized to engage in transactions related to the provision of medicine, medical devices, and medical services involving OFAC-designated Orka Holding and its subsidiaries. Read more.
Iran-related Sanctions
- OFAC Designates Iran-Aligned Militias in Iraq: OFAC on Nov. 17 designated six individuals affiliated with the Iran-aligned militia group, Kata’ib Hizballah (KH) based in Iraq. KH is trained, funded, and supported by Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) and responsible for recent attacks against the United States, and partners in Iraq and Syria following the attacks by Hamas against Israel. The U.S. Department of State is also designating Kata’ib Sayyid al-Shuhada (KSS) and KSS leader Hashim Finyan Rahim al-Saraji. KSS, another Iraq-based IAMG that receives support from the IRGC, has planned and been involved in attacks against U.S. personnel in Iraq and Syria. See the identifying information on the designees. Read more.
Venezuela-related Sanctions
- OFAC Partially Eases Venezuelan Aviation Sanctions: OFAC on Nov. 17 permitted maintenance on Venezuelan state-owned Conviasa’s Embraer fleet and authorizing transactions necessary to the repatriation of Venezuelan nationals. OFAC issued four new Venezuela-related Frequently Asked Questions 1141-1144. FAQs 1141-1144 answer questions related to General License 45A. FAQ 1144 answers whether or not GL 45A authorizes U.S. persons to provide services to blocked Conviasa aircraft carrying out non-commercial flights between a third country in the Western Hemisphere and Venezuela. FAQ 1143 clarifies the term “non-commercial” as it relates to GL 45A. FAQ 1142 answers whether or not GL 45A authorizes U.S. persons to provide maintenance services to Conviasa aircraft. FAQ 1141 answers whether or not GL 45A authorizes U.S. persons to provide refueling services to Conviasa aircraft that are carrying out flights repatriating Venezuelan nationals. Read more.
Terrorism-related Sanctions
- OFAC Imposes Further Sanctions Targeting Hamas: OFAC on Nov. 14 imposed its third round of sanctions targeting Hamas-affiliated individuals and entities since the October 7 Hamas terrorist attacks on Israel. OFAC’s action designates key Hamas officials and the mechanisms by which Iran provides support to Hamas and Palestinian Islamic Jihad (PIJ). The designations are coordinated with action by the U.K. and are aimed at protecting the international financial system from abuse by Hamas and their enablers. The U.S. Department of State is concurrently designating a leader of PIJ’s military wing. Read more.
Illicit drug-related Sanctions
- OFAC Designates Costa Rican Narcotics Trafficker: OFAC on Nov. 15 designated Gilbert Hernan de Los Angeles Bell Fernandez, a Costa Rican narcotics trafficker, known not only for the volume of drugs he moves but the violence with which he operates. Bell has played a significant role in Costa Rica’s recent transformation into a major narcotics transit hub. He was arrested by Costa Rican authorities in 2015 on drug-related charges and has had property seized by Costa Rican authorities in multiple raids, including several boats allegedly used for drug transshipment. Read more.
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