The Office of Foreign Assets Control announced the following sanctions action last week.
Enforcement Action
- Aiotec GmbH Settles with OFAC for Apparent Violation of the Iranian Sanctions Regulations: OFAC on Dec. 3 announced a $14,550,000 settlement with Aiotec GmbH. Aiotec, a Berlin, Germany-headquartered company that sources industrial equipment for the energy sector, has agreed to settle its potential civil liability for one apparent violation of the Iranian Transactions and Sanctions Regulations. The apparent violation arose from Aiotec’s participation in a conspiracy between 2015 and 2019 to cause a U.S. company to indirectly sell and supply an Australian polypropylene plant to Iran, and remit payments for the sale of the plant through U.S. financial institutions. This settlement amount reflects OFAC’s determination that Aiotec’s conduct was not voluntarily self-disclosed and constituted an egregious case. Read more.
Corruption and Human Rights Abuse Designations
- OFAC Recognizes International Human Rights Day, Designates Individuals and Entity: In recognition of International Human Rights Day, OFAC on Dec. 9 announced new designations and highlighted other human rights-related sanctions actions taken over the last year. IHRD is observed annually on December 10 in commemoration of the United Nations’ adoption of the Universal Declaration of Human Rights on that day in 1948. OFAC designated Houthi National Committee for Prisoners’ Affairs and its leader, Abdulqader Al-Murtadha for their roles in human rights abuses against prisoners held in Houthi-run prisons in Yemen. OFAC also designated Fawaz al-Akhras for providing support to Bashar al-Assad. Concurrent with the Treasury’s action, the Department of State announced steps to impose visa restrictions on dozens of individuals pursuant to Section 212(a)(3)(C) of the Immigration and Nationality Act, and designated one official under Section 7031(c) of the annual Appropriations Act for involvement in a gross violation of human rights. Read more.
- OFAC Sanctions Global Gold Smuggling Network of Kamlesh Pattni: OFAC sanctioned 28 individuals and businesses involved in a global gold smuggling and money laundering network based in Zimbabwe, pursuant to Executive Order 13818, which targets perpetrators of serious human rights abuse and corruption around the world. OFAC designated the global network led by Kamlesh Pattni for bribing officials, deploying trusted supporters to mask ownership, and weaving a global web of businesses to hide the illicit activities. This fraudulent scheme has robbed Zimbabwe’s citizens of the benefit of those natural resources while enriching corrupt government officials and criminal actors. Read more.
- OFAC Sanctions Former Uzbekistan Government Officials: OFAC on Dec. 2 sanctioned three former Government of Uzbekistan officials who were involved in human trafficking and gender-based violence, including physical and sexual violence against children at a state-run orphanage in Urgench, Uzbekistan. All three individuals—Yulduz Khudaiberganova, Anvar Kuryazov, and Aybek Masharipov—were designated pursuant to Executive Order 13818, which builds upon and implements the Global Magnitsky Human Rights Accountability Act and targets perpetrators of serious human rights abuse around the world. Read more.
Russia-related Sanctions
- OFAC Sanctions Money Laundering Network Using Digital Assets to Evade Sanctions: OFAC on Dec. 4 sanctioned five individuals and four entities that are associated with, or leverage the TGR Group. The TGR Group is an extensive sanctions evasion and money laundering network that works to obfuscate the illicit activities of Russian elites, including through the use of digital assets. OFAC identified a Wyoming-based entity, Pullman Global Solutions LLC which is owned by a sanctioned individual, Andrejs Bradens. Bradens, a Latvian national, is associated with multiple TGR Group companies. These designations are the result of a collaborative effort with the United Kingdom’s National Crime Agency, the United Arab Emirates government, the Drug Enforcement Administration, and the Financial Crimes Enforcement Network. Read more.
Iran-related Sanctions
- OFAC Sanctions Iranian Entities and Vessels: OFAC on Dec. 3 sanctioned 35 entities and vessels that play a critical role in transporting illicit Iranian petroleum to foreign markets. OFAC’s action imposes additional costs on Iran’s petroleum sector following Iran’s attack against Israel on Oct. 1, 2024, as well as Iran’s announced nuclear escalations. Petroleum revenues provide the Iranian regime with the resources to fund its nuclear program, develop advanced drones and missiles, and provide ongoing financial and material support for the terrorist activities of its regional proxies. Read more.
Venezuela-related Sanctions
- OFAC Sanctions Officials Aligned with Maduro: OFAC on Nov. 27 sanctioned 21 security and cabinet-level officials aligned with Venezuelan President Nicolas Maduro. These individuals are sanctioned pursuant to Executive Order 13692 for being current or former officials of the Government of Venezuela. The designees have supported and carried out Maduro’s orders to repress civil society in his efforts to fraudulently declare himself the winner of Venezuela’s July 28 presidential election. Read more.
Illicit Drug-related Sanctions
- OFAC Sanctions Individuals Associated with Gulf Cartel’s Unregulated Fishing Operations: OFAC on Nov. 26 sanctioned five Mexican individuals pursuant to Executive Order 14059 for their involvement in the Gulf Cartel’s criminal activities including illegal, unreported, and unregulated (IUU) fishing, human smuggling, and narcotics trafficking in the Gulf of Mexico. IUU fishing often involves criminal activity, forced labor, and human rights abuses, and is often a revenue stream for criminal organizations. IUU fishing is also a threat to U.S. maritime security, as criminal organizations may use the same vessels for smuggling narcotics and humans across borders. The designees are Ismael Guerra Salinas (a.k.a. Mayelo); Ismael’s brother, Omar Guerra Salinas (a.k.a. Samorano); Francisco Javier Sierra Angulo (a.k.a. El Borrado); Raul Decuir Garcia (a.k.a. La Burra) and Ildelfonso Carrillo Sapien (a.k.a. El Chivo). Read more.
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