The Office of Foreign Assets Control announced the following sanctions action last week.
Enforcement Action
- OFAC Announces Settlement Agreement with an Individual and with Córdoba Music Group LLC: OFAC on Dec. 18 announced a settlement with an individual (“U.S. Person-1”). U.S. Person-1 agreed to remit $45,179 to settle their potential civil liability for six apparent violations of OFAC’s Global Magnitsky Sanctions Regulations. Between January 2021 and June 2021, U.S. Person-1 executed six payments totaling $45,179 on behalf of a blocked individual with knowledge that the individual was sanctioned. The settlement amount reflects OFAC’s determination that the apparent violations were not self-disclosed and that three of the apparent violations were egregious. Separately, OFAC announced a settlement with Córdoba Music Group LLC (Córdoba). Córdoba, a manufacturer of musical instruments based in California, agreed to remit $41,591 to settle its potential civil liability for apparent violations of sanctions on Iran.
Russia-related Sanctions
- OFAC Issues Russia-related General Licenses and FAQ: OFAC on Dec. 18 issued Russia-related General License 1B, “Authorizing Certain Activities Involving Federal State Budgetary Institution Marine Rescue Service,” and Russia-related General License 115 “Authorizing Transactions Involving Gazprombank Related to Civil Nuclear Energy.” OFAC also issued one amended, Russia-related FAQ 894 and one new, Russia-related FAQ 1203.
Balkans-related Sanctions
- OFAC Targets Financial and Political Enablers of Republika Srpska President Milorad Dodik: OFAC on Dec. 18 sanctioned three individuals and four entities in Bosnia and Herzegovina (BiH) that form part of U.S.-designated Republika Srpska (RS) President Milorad Dodik’s financial network. OFAC’s action also targets a BiH politician who serves as a key enabler of Dodik’s corruption and destabilizing political agenda. Read more.
Iran-related Sanctions
- OFAC Sanctions Entities and Vessels Involved in the Trade of Iranian Petroleum and Petrochemicals: OFAC on Dec. 19 sanctioned four entities and three vessels involved in the trade of Iranian petroleum and petrochemicals, which generate billions of dollars’ worth of revenue for the Iranian regime. This revenue supports Iran’s nuclear program, its development and proliferation of provocative ballistic missiles, and financing of terrorist proxy groups such as Hizballah, Hamas, and the Houthis. Vessels transporting Iranian petroleum and petrochemicals frequently use methods of obfuscation and deception to mask this trade, posing a significant danger to the maritime industry. Concurrently, the U.S. Department of State is taking action against four entities in multiple jurisdictions involved in the movement of Iranian petroleum. Read more.
- OFAC Sanctions Entities and Individuals Supporting the Iranian Military: OFAC on Dec. 18 sanctioned two entities and two individuals for their roles in developing and procuring components for sensitive navigational systems for the Iranian military. The Islamic Revolutionary Guard Corps Aerospace Force Self-Sufficiency Jihad Organization (IRGC ASF SSJO) and other Iranian organizations rely on these strategic components that are necessary for the production and proliferation of unmanned aerial vehicles (UAVs) and missiles. Concurrent with this action, the U.S. Department of State is designating one individual and two entities involved in Iranian UAV and missile development. OFAC’s action was taken in coordination with the Department of Commerce and the Department of Justice. Read more.
North Korea-related Sanctions
- OFAC Sanctions North Korean Crypto Network: OFAC on Dec. 17 sanctioned two individuals and one entity involved in a network that launders millions of dollars of illicit funds generated by North Korean IT workers to support the North Korean government. The two designated individuals, Lu Huaying and Zhang Jian are based in the United Arab Emirates. Lu Huaying and Zhang Jian worked through a UAE-based front company, Green Alpine Trading, LLC to facilitate money laundering and cryptocurrency conversion services that funneled the illicit proceeds back to North Korea. Read more.
Terrorism-related Sanctions
- OFAC Targets Houthi Procurement and Financing Schemes: OFAC on Dec. 19 sanctioned a dozen individuals and entities based in multiple jurisdictions, including the head of the Houthi-aligned Central Bank of Yemen branch in Sana’a, for their roles in trafficking arms, laundering money, and shipping illicit Iranian petroleum for the benefit of the Houthis. Among the designees are key smuggling operatives, arms traffickers, and shipping and financial facilitators who have enabled the Houthis to acquire and transport an array of dual-use and weapons components, as well as generate revenue to support their destabilizing regional activities. Additionally, OFAC identified five cryptocurrency wallets associated with Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF)-backed Houthi financial official Sa’id al-Jamal (al-Jamal), who operates under the aliases “Khrpi,” “Ahmad Sa’idi,” and “Hisham,” among others. Read more.
Corruption and Human Rights Abuse Designations
- OFAC Sanctions Georgian Government Officials for Brutality Against Protesters, Journalists, and Politicians: OFAC on Dec. 19 sanctioned two Georgian officials from Georgia’s Ministry of Internal Affairs which has engaged in brutal crackdowns on media members, opposition figures, and protesters — including during demonstrations throughout 2024. These officials are being sanctioned under Executive Order 13818 (Global Magnitsky), following the Sept. 16, 2024 sanctions of two other Georgian Ministry of Internal Affairs officials. This action was coordinated with the United Kingdom, which designated five individuals responsible for human rights violations in Georgia. Read more.
Illicit Drug-related Sanctions
- OFAC Designates Individuals and Entities for Global Illicit Drug Trade: OFAC on Dec. 17 sanctioned 12 individuals and eight entities based in Europe, Latin America and the Pacific for their links to the global illicit drug trade. The designees include Lithuanian nationals Rokas Karpavicius, Virginijus Labutis, Saulius Staskus and their associates from Australia, David Jonathan Thackray and New Zealand, Ho Kai Leung. OFAC also sanctioned Colombia-based narcotics traffickers Allende Perilla Sandoval, Camilo Esteban Betancourt Rosero, Orozman Orlando Osten Blanco, Elkin Casarrubia Posada, and Luis Perez Castaneda. The designated entities are owned or controlled by the designated individuals. OFAC’s action, taken pursuant to Executive Order 14059, underscores the United States’ commitment to combating the synthetic drug threat at home and abroad. Read more.
