Recent news from Treasury’s Office of Foreign Assets Control: December 15

Enforcement Action

• OFAC Announces Settlement with CoinList Markets LLC: The Office of Foreign Assets Control on Dec. 13 announced a $1,207,830 settlement with CoinList Markets LLC for processing 989 transactions, conduct deemed non-egregious, but not voluntarily self-disclosed. CoinList required users to provide physical addresses and took measures to monitor the IP addresses and physical addresses of users, rejecting transactions from sanctioned jurisdictions. However, these measures missed certain users; CoinList opened 89 accounts for customers who generally specified they were residents of Russia, but provided physical addresses which included Crimean cities. Read more.

The Office of Foreign Assets Control took significant sanctions actions over the last week in the Russia, terrorism and transnational criminal organizations programs:

• U.S Sanctions More than 150 Individuals and Entities: The United States on Dec. 12 sanctioned more than 150 individuals and entities complicit in furthering Russia’s ability to wage its war against Ukraine, and responsible for bolstering Russia’s future energy production and export capacity. OFAC took action against actors who materially support Russia’s war; targeting Russian military procurement networks and those who help Russia acquire machine tools, equipment, and key inputs; and further curtailing Russia’s use of the international financial system to further its war in Ukraine. The Department of State concurrently imposed sanctions on over 100 entities and individuals, including those engaged in sanctions evasion in numerous third countries, complicit in furthering Russia’s ability to wage its war against Ukraine, and responsible for bolstering Russia’s future energy production and export capacity. Read more.

• U.S. and U.K. Target IRGC-QF, Hamas and Palestinian Islamic Jihad: OFAC and the United Kingdom on Dec. 14 jointly took action against Iran’s Islamic Revolutionary Guard Corps – Qods Force (IRGC-QF), Hamas, and Palestinian Islamic Jihad (PIJ). The U.K. is taking its first action pursuant to new Iran-related authorities, targeting eight actors, including the head of the IRGC-QF, and individuals linked to Iran’s support for Hamas and PIJ. OFAC designated IRGC-QF official Majid Zaree, who is involved in the IRGC-QF’s support to groups such as Hizballah and Hamas. The U.K. sanctioned eight actors affiliated with the IRGC-QF, Hamas, or PIJ, seven of whom have previously been designated by OFAC, including IRGC-QF commander Esmail Qaani and senior IRGC-QF official Muhammad Sa’id Izadi. IRGC-QF support has enabled Hamas’ and PIJ’s terrorist activities, to include the transfer of hundreds of millions of dollars in financial assistance and provision of weapons and operational training. Read more.
• In related news, OFAC on Dec. 13 imposed a fourth round of sanctions on Hamas since the Oct. 7 terrorist attack on Israel. OFAC’s designated key Hamas officials who perpetuate Hamas’s violent agenda by representing the group’s interests abroad and managing its finances. OFAC closely coordinated with the United Kingdom to concurrently designate several key Hamas officials. Read more.

• OFAC Sanctions Malas Mañas TCO and Human Smugglers: OFAC on Dec. 14 sanctioned the Malas Mañas transnational criminal organization (TCO), a human smuggling and narcotics trafficking organization based in Sonora, Mexico. The organization smuggles undocumented non-citizens — often individuals from Guatemala and El Salvador — through Sonora, across the U.S. Southwest Border, and into Arizona, including Phoenix and Tucson. Malas Mañas is also involved in narcotics trafficking and weapons trafficking. Specifically, Malas Mañas has distributed illicit fentanyl, cocaine, and methamphetamine in the United States. In addition to Malas Mañas, OFAC also sanctioned two Mexico-based human smugglers, Luis Eduardo Roman Flores and Joel Alexandro Salazar Ballesteros pursuant to E.O. 13581, Blocking Property of Transnational Criminal Organizations, for acting on behalf of Malas Mañas. Read more.