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Recent news from Treasury’s Office of Foreign Assets Control: February 22

February 22, 2024
Reading Time: 3 mins read
AML Innovation and Whistleblower Provisions of the NDAA Mean Important Changes Ahead

The Office of Foreign Assets Control took sanctions action over the last few weeks in the Russia, Iran, North Korea and cyber-related programs:

Russia-related Sanctions

  • U.S. Sanctions Hundreds of Targets in Russia Following the Death of Aleksey Navalny: OFAC, along with the U.S. Department of State designated three Russian government officials in connection with the death of anti-corruption activist and political prisoner, Aleksey Navalny. Together, Treasury and State sanctioned over 500 targets to impose additional costs for Russia’s repression, human rights abuses, and aggression against Ukraine. The Department of Commerce also added more than 90 companies to its Entity List. The United States is targeting Russia’s core financial infrastructure, including the operator of the Mir National Payment System and Russian banks, investment firms, and financial technology companies, to further implement G7 commitments to curtail Russia’s use of the international financial system to further its war against Ukraine. Among the designees include National Payment Card System Joint Stock Company, Avangard Joint Stock Bank, Bank RostFinance, Joint Stock Commercial Bank Chelindbank, Joint Stock Commercial Bank International Financial Club, Joint Stock Commercial Bank Modulbank, Joint Stock Company Databank, Maritime Joint Stock Bank Joint Stock Company, Public Joint Stock Company Bystrobank, Public Joint Stock Company SPB Bank, and several investment firms and venture capital funds. Read more.
  • OFAC Designates Russia’s Largest Shipping Company: OFAC on Feb. 23 designated Joint Stock Company Sovcomflot, Russia’s state-owned shipping company and fleet operator. In addition to designating Sovcomflot, OFAC identified 14 crude oil tankers as property in which Sovcomflot has an interest. A new Treasury analysis found that the United States’ increased sanctions enforcement is forcing Russia to sell oil at a steeper discount and limiting their revenue. Read more.

Iran-related Sanctions

  • OFAC Sanctions Procurement Network Supporting Export of Goods and Technology in Iran: OFAC on Feb. 14 sanctioned a procurement network responsible for facilitating the illegal export of goods and technology from over two dozen U.S. companies to end-users in Iran, including the OFAC-designated Central Bank of Iran (CBI) for its role in providing financial support to the Islamic Revolutionary Guard Corps-Qods Force and Hizballah. These designations target three individuals and four entities tied to the procurement of sophisticated U.S. technology for use by CBI in violation of U.S. export restrictions and sanctions. Among the goods and technology acquired by CBI were items classified as information security items subject to national security and anti-terrorism controls by the U.S. Department of Commerce’s Bureau of Industry and Security. Read more.

North Korea-related Sanctions

  • OFAC Amends North Korea Regulations to Allow Humanitarian Efforts, Issues FAQs: OFAC on Feb. 15 amended the North Korea sanctions regulations to amend or add general licenses to facilitate certain humanitarian-related and journalistic activities. OFAC amended an existing general license for nongovernmental organizations and added general licenses to authorize certain transactions related to the exportation and re-exportation of items authorized by the U.S. Department of Commerce; the provision of certain agricultural commodities, medicine, and medical devices; and certain journalistic activities in North Korea.
  • Related to this action, OFAC issued new North Korea-related Frequently Asked Questions 1160, 1161, 1162, 1163 and amended FAQs 459, 463, 558. Read more.

Cyber-related Sanctions

  • OFAC Designates Individuals Affiliated with Ransomware Group LockBit: OFAC on Feb. 20 designated two individuals who are affiliated with the Russia-based ransomware group LockBit. LockBit operates on a Ransomware-as-a-Service (RaaS) model, where the group licenses its ransomware software to affiliated cybercriminals in exchange for a percentage of the paid ransoms. LockBit is known for its double extortion tactics, where its cybercriminals exfiltrate vast amounts of data from its victims before encrypting the victim’s computer systems and demanding ransom payments. OFAC designated Ivan Gennadievich Kondratiev and Artur Sungatov pursuant to Executive Order 13694 Blocking the Property of Certain Persons Engaging in Significant Malicious Cyber-Enabled Activities, as amended by E.O. 13757, for being responsible for or complicit in, or having engaged in, directly or indirectly, an activity described in subsection (a)(ii)(D) of section 1 of E.O. 13694, as amended. This action is the first in an ongoing collaborative effort with the U.S. Department of Justice, Federal Bureau of Investigation, and international partners targeting LockBit. Read more.

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