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Recent news from Treasury’s Office of Foreign Assets Control: December 1

December 1, 2023
Reading Time: 3 mins read
AML Innovation and Whistleblower Provisions of the NDAA Mean Important Changes Ahead

OFAC took a number of significant sanctions actions over the last week across multiple programs:

Russia-related Sanctions

  • OFAC Imposes Additional Price Cap-Related Sanctions: OFAC on Dec. 1 imposed sanctions on three entities and identified as blocked property three vessels that used Price Cap Coalition services while carrying Russian crude oil above the Coalition-agreed price cap. OFAC sanctioned HS Atlantica Limited, Sterling Shipping Incorporated and Streymoy Shipping Limited. OFAC identified vessels HS Atlantica (5Lip5), NS Champion (A8FD9) and Viktor Bakaev (D5BN6). Read more.
  • Related to this action, OFAC issued Russia-related General License 78, “Authorizing Limited Safety and Environmental Transactions Involving Certain Persons or Vessels Blocked on December 1, 2023.” GL 78 authorizes certain transactions involving the blocked persons or vessels through Feb. 29, 2024. Read more.

Iran-related Sanctions

  • OFAC Sanctions Large Iranian Military Financial Facilitation Networks: OFAC on Nov. 29 sanctioned over 20 individuals and entities for their involvement in financial facilitation networks for the benefit of Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL), Iranian Armed Forces General Staff (AFGS) and the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF). Iran generates the equivalent of billions of dollars via commodity sales to fund its destabilizing regional activities and support of multiple regional proxy groups, including Hamas and Hizballah. MODAFL, the AFGS and the IRGC-QF utilize intricate networks of foreign-based front companies and brokers to enable these illicit commercial activities and exploit the international financial system. Read more. See the identifying information on the designees.

North Korea-related Sanctions

  • OFAC Sanctions North Korean Mixer Used to Launder Stolen Virtual Currency: OFAC on Nov. 29 sanctioned Sinbad.io (Sinbad), a virtual currency mixer that serves as a key money-laundering tool of the OFAC-designated Lazarus Group, a North Korean cyber hacking group. Sinbad has processed millions of dollars’ worth of virtual currency from Lazarus Group heists, including the Horizon Bridge and Axie Infinity heists. Sinbad is also used by cybercriminals to obfuscate transactions linked to malign activities such as sanctions evasion, drug trafficking, the purchase of child sexual abuse materials, and additional illicit sales on darknet marketplaces. Read more.
  • OFAC Targets North Korea’s International Agents and Illicit Cyber Intrusion Group: OFAC on Nov. 30 sanctioned eight foreign-based North Korean agents that facilitate sanctions evasion, including revenue generation and missile-related technology procurement that support North Korea’s weapons of mass destruction (WMD) programs. Additionally, OFAC sanctioned cyber espionage group Kimsuky for gathering intelligence to support North Korea’s objectives. OFAC’s actions target North Korea’s access to revenue and weapons, generated through state-owned entities, banks, and trading companies, specifically through their globally deployed trade and bank representatives. Among the designees include Green Pine Associated Corporation, Foreign Trade Bank of the Democratic People’s Republic of Korea, KoryoCommercial Bank LTD., Korea United Development Bank, and Mansudae Overseas Project Group of Companies. Read more.

Corruption and Human Rights Abuse Designations

  • OFAC Sanctions Former Guatemalan Government Official: OFAC on Dec. 1 sanctioned former head of the now-defunct Centro de Gobierno, Luis Miguel Martinez Morales for his role in corruption in Guatemala wherein he engaged in widespread bribery schemes, including schemes related to government contracts. While in office, Martinez influenced the government contracts process to benefit himself and close associates. In 2021, Martinez solicited large kickbacks to facilitate the purchase of the Russian Sputnik V vaccines by the Government of Guatemala. Martinez is being designated pursuant to Executive Order 13818, which builds upon and implements the Global Magnitsky Human Rights Accountability Act and targets perpetrators of serious human rights abuse and corruption around the world. Read more.

Illicit drug-related Sanctions

  • OFAC Sanctions CJNG Timeshare Fraud Network: OFAC on Nov. 30 sanctioned three Mexican individuals and 13 Mexican companies linked to OFAC-designated Cartel de Jalisco Nueva Generacion (CJNG). The designees are linked to timeshare fraud led by CJNG. CJNG, a violent Mexico-based organization, traffics a significant proportion of the illicit fentanyl and other deadly drugs that enter the United States. OFAC coordinated this action with the Government of Mexico, including its Financial Intelligence Unit, as well as U.S. Government partners, including the Federal Bureau of Investigation, and the Drug Enforcement Administration. OFAC’s action is the third action this year against CJNG timeshare fraud. Read more. See the list of designees.

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