The Office of Foreign Assets Control announced the following sanctions action last week.
Enforcement Action
- OFAC Issues a Penalty Notice to an Individual: OFAC on Nov. 19 announced the issuance of a $1,104,408 penalty against an individual for 75 violations of OFAC sanctions on Iran. The violations related to the individual’s use of an informal value transfer system to remit funds between the United States and Iran in order to purchase, renovate, and operate a hotel in Iran. The penalty amount reflects OFAC’s determination that the violations were egregious and were not voluntarily self-disclosed. Read more.
Russia-related Sanctions
- OFAC Sanctions Russian Network of Banks, Securities Registrars and Finance Officials: OFAC on Nov. 21 sanctioned dozens of Russian banks, securities registrars, and finance officials to curtail Russia’s use of the international financial system to further its war against Ukraine. OFAC’s action includes the designation of Gazprombank, more than 50 internationally connected Russian banks, more than 40 Russian securities registrars, and 15 Russian finance officials. Related to this action, OFAC issued an alert describing sanctions risks related to Russia’s System for Transfer of Financial Messages, which the Kremlin created and uses to evade sanctions. Read more.
- OFAC issued Russia-related GL 53A, “Authorizing Transactions for Diplomatic Missions of the Russian Federation Involving Gazprombank Joint Stock Company or Prohibited by Directive 4 under Executive Order 14024,” Russia-related GL 55C, “Authorizing Certain Services Related to Sakhalin-2,” Russia-related GL 113, “Authorizing the Wind Down of Transactions Involving Certain Financial Institutions Blocked on November 21, 2024,” and Russia-related GL 114, “Authorizing Certain Transactions Related to Debt or Equity of, or Derivative Contracts Involving, Certain Entities Blocked on November 21, 2024.”
- Additionally, OFAC issued new Russia-related Frequently Asked Question 1201 to answer authorizations related to U.S. and third-country diplomatic or consular missions operating in Russia, and 1202 to answer if the Nov. 21 designation of Russian financial institutions negatively impact the processing of personal, non-commercial remittances to or from Russia. Finally, OFAC amended three Russia-related Frequently Asked Questions (FAQ 976, FAQ 1096, FAQ 1197).
Terrorism-related Sanctions
- OFAC targets key Hamas leaders and financiers: OFAC on Nov. 19 designated six senior Hamas officials, including the terrorist group’s representatives abroad, a senior member of the Hamas military wing, the Izz Al-Din Al-Qassam Brigades, as well as individuals involved in supporting the terrorist group’s fundraising efforts and weapons smuggling into Gaza. Read more.
Illicit Drug-related Sanctions
- OFAC Sanctions Fentanyl Traffickers and Other Key Contributors to U.S. Opioid Crisis: OFAC on Nov. 19 sanctioned a network of nine Mexican nationals involved in fentanyl, heroin, and other deadly drug trafficking and money laundering. Individuals designated in this network also engage in human smuggling in furtherance of their drug trafficking activities. Additionally, as members of the Cartel Jalisco Nueva Generacion (CJNG), some of the sanctioned individuals played a prominent role in the early stages of the U.S. opioid crisis, a leading factor driving the United States’ modern fentanyl crisis. CJNG is a violent Mexico-based drug trafficking organization responsible for a significant proportion of fentanyl and other deadly drugs trafficked into the United States. Read more.