The Office of Foreign Assets Control announced the following sanctions action last week:
OFAC FAQs Update
- OFAC Issues New and Amended Insurance-related FAQs: OFAC on Nov. 13 amended Frequently Asked Questions 61, 62, 63, 64, 65, 68, 69, 102, 103, and 104 as part of its ongoing process of reviewing published guidance to ensure information remains current. This batch includes review of OFAC’s FAQ Topic Page, Compliance for the Insurance Industry. OFAC is also publishing two new insurance-related FAQs 1199 and 1200. Read more.
Enforcement Actions
- OFAC Announces $178,421 Settlement with ALICO for Iran Sanctions Violations: OFAC on Nov. 14 announced a $178,421 settlement with American Life Insurance Company (ALICO), a subsidiary of MetLife, Inc. for its potential civil liability regarding 2,331 apparent violations of OFAC sanctions on Iran. The apparent violations related to insurance policies provided to entities in the United Arab Emirates that were owned or controlled by the Government of Iran. The settlement amount reflects OFAC’s determination that the apparent violations were voluntarily self-disclosed and were not egregious. Read more.
Sudan-related Sanctions
- OFAC Sanctions Sudanese Commander: OFAC on Nov. 12 sanctioned Abdel Rahman Joma’a Barakallah for his leadership role in the Rapid Support Forces (RSF), a primary party responsible for the ongoing violence against civilians in Sudan since April 2023. Barakallah led the RSF’s campaign in West Darfur, which was marked by credible claims of serious human rights abuses, including targeting of civilians, conflict-related sexual violence, and ethnically motivated violence. This action is in furtherance of the United Nations Security Council’s Nov. 8 designation of Barakallah and fellow RSF commander Osman Mohamed Hamid Mohamed, who was previously designated by the Department of the Treasury in May 2024. Read more.
Terrorism-related Sanctions
- OFAC Targets Syrian Network Funding Qods Force and Houthis: OFAC on Nov. 14 sanctioned 26 companies, individuals, and vessels associated with the Al-Qatirji Company, a Syrian conglomerate responsible for generating hundreds of millions of dollars in revenue for Iran’s Islamic Revolutionary Guard Corps-Qods Force and the Houthis through the sale of Iranian oil to Syria and the People’s Republic of China. Previously designated for its role in facilitating the sale of fuel between the Syrian regime and ISIS, the Al-Qatirji Company has morphed into one of the main channels through which the IRGC-QF generates revenue and funds its regional proxy groups. OFAC is expanding its targeting of Al-Qatirji’s network and its fleet of vessels to inhibit the IRGC-QF from benefiting from this relationship. Read more.
