Enforcement Action
- OFAC Announces Settlement Agreement with PURE for Ukraine-/Russia Sanctions Violations: The Office of Foreign Assets Control on Dec. 21 announced a $466,200 settlement with Privilege Underwriters Reciprocal Exchange (PURE). The agreement settles PURE’s potential civil liability for 39 apparent violations of OFAC’s Ukraine-/Russia-Related sanctions. Specifically, between May 2018 and July 2020, PURE engaged in transactions related to four insurance policies involving a blocked Panama-based company owned by Specially Designated National, Viktor Vekselberg (who was not designated at the time the policies were issued). The settlement amount reflects OFAC’s determination that PURE’s apparent violations were not voluntarily self-disclosed and were non-egregious. Read more.
The Office of Foreign Assets Control took a number of significant sanctions actions on the Russia, Iran and terrorism related programs:
Russia-related Sanctions
- OFAC Designates Russia-owned Ship Manager and Others, Updates Guidance on Price Cap Policy for Crude Oil: OFAC on Dec. 20 designated a Russia-owned ship manager as well as several oil traders who are frequent participants in the seaborne transportation of Russian-origin oil following the imposition of the price cap. OFAC also updated the Guidance on Implementation of the Price Cap Policy for Crude Oil and Petroleum Products of Russian Federation Origin. OFAC’s actions are in line with commitments made by Leaders of the Group of Seven (G7) on Dec. 6, 2023 to tighten compliance and enforcement of the price cap policy on Russian oil, including by imposing sanctions on those engaged in deceptive practices and by updating compliance rules and regulations as necessary. Read more.
- See the list of Russia-related updates in late December, including a general license authorizing certain transactions related to imports of certain fish, seafood, a general license authorizing certain transactions related to closing a correspondent or payable-through account, and the publication of 12 new Russia-related FAQs 1146-1157 and amended FAQs 973, 1070, and 1126.
- OFAC also published guidance for financial institutions on OFAC sanctions authorities targeting support to Russia’s military-industrial base.
Iran-related Sanctions
- OFAC Sanctions Procurement Network Across Middle East and East Asia Supporting Iran’s UAV Program: OFAC on Dec. 19 imposed sanctions on 10 entities and four individuals based in Iran, Malaysia, Hong Kong, and Indonesia for supporting Iran’s unmanned aerial vehicle (UAV) production. This network, led by Iran-based Hossein Hatefi Ardakani, has facilitated the procurement of U.S.- and foreign-origin components worth hundreds of thousands of dollars for the Islamic Revolutionary Guard Corps Aerospace Force Self Sufficiency Jihad Organization (IRGC ASF SSJO) and its UAV program. Read more.
Terrorism-related Sanctions
- OFAC Targets Network Financing Houthis: OFAC on Dec. 28 designated one individual and three entities responsible for facilitating the flow of funds to Houthi forces and their destabilizing activities. Among the designees is Nabil Ali Ahmed Al-Hadha, the head of the Currency Exchangers Association in Sana’a, and three exchange houses in Yemen and Türkiye: Al Aman Kargo Ithalat Ihracat Ve Nakliyat Limited Sirketi, Nabco Money Exchange and Remittance Co. and Al Rawda Exchange and Money Transfers Company. The designated individuals have facilitated the transfer of millions of dollars to the Houthis at the direction of U.S.-designated Sa’id al-Jamal, who is affiliated with Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF). Read more.
