The Office of Foreign Assets Control announced the following sanctions action last week.
Russia-related Sanctions
- OFAC Targets Russia’s Oil Production and Exports: OFAC on Jan. 10 imposed sanctions on a number of oil-carrying vessels, including blocking two major Russian oil producers. This action was intended to fulfill a G7 commitment to reduce Russian revenues from energy. Many of the designees are part of the “shadow fleet,” opaque traders of Russian oil, Russia-based oilfield service providers, and Russian energy officials. Among the designees include Joint Stock Company Surgutneftegasbank (SNGB), a Russia-based commercial bank. These actions substantially increase the sanctions risks associated with the Russian oil trade. Read more.
- OFAC’s actions are underpinned by the issuance of a new determination,“Energy Sector of the Russian Federation Economy,” that authorizes sanctions pursuant to Executive Order 14024 against persons operating or having operated in the energy sector of the Russian Federation economy. OFAC published the Determination pursuant to Section 1(a)(i) of Executive Order 14024. Read more.
- Related to this action, OFAC also issued a new determination prohibiting the provision of U.S. petroleum services, “Prohibition on Petroleum Services,” pursuant to Section 1(a)(ii) of Executive Order 14071. Read more.
- In addition, OFAC issued Russia-related General Licenses 8L, 115A, 117, 118, 119, 120, 121 and Russia-/Ukraine-related General License 26. OFAC revoked Russia-related General License 93, “Authorizing Transactions Involving Certain Sovcomflot Vessels.” Finally, OFAC issued five new, Russia-related Frequently Asked Questions 1213 – 1217, and amended 14 Russia-related Frequently Asked Questions 967, 976, 977, 978, 999, 1011, 1012, 1017, 1117, 1126, 1182, 1183, 1201, and 1203. Read more.
- OFAC Issues Russia-related General License 13L: OFAC on Jan. 7 issued Russia-related General License 13L to authorize certain administrative transactions prohibited by Directive 4 under Executive Order 14024 through April 9, 2025. Effective Jan. 7, 2025, General License No. 13K, dated Sept. 30, 2024, is replaced and superseded in its entirety by this General License No. 13L. Read more.
Balkans-related Sanctions
- President Signs Executive Order on Taking Additional Steps with Respect to the Situation in the Western Balkans: President Biden on Jan. 8 signed a new Executive Order (E.O.) “Taking Additional Steps with Respect to the Situation in the Western Balkans.” Read more.
Syria-related Sanctions
- OFAC Issues Sanctions Relief for Syrian People: OFAC on Jan. 6 issued Syria General License 24 to expand authorizations for additional sanctions relief for Syrian people. OFAC’s action underscores the United States’ commitment to ensuring that U.S. sanctions do not impede activities to meet basic human needs, including the provision of public services or humanitarian assistance. This authorization is for six months, as the U.S. government continues to monitor the evolving situation on the ground. Read more.
Sudan-related Sanctions
- OFAC Sanctions Sudanese Paramilitary Leader, Weapons Supplier, and Related Companies: OFAC on Jan. 7 sanctioned Mohammad Hamdan Daglo Mousa, leader of Sudan’s Rapid Support Forces (RSF), under Executive Order (E.O.) 14098, “Imposing Sanctions on Certain Persons Destabilizing Sudan and Undermining the Goal of a Democratic Transition.” For nearly two years, Hemedti’s RSF has engaged in a brutal armed conflict with the Sudanese Armed Forces for control of Sudan, killing tens of thousands, displacing 12 million Sudanese, and triggering widespread starvation. Additionally, OFAC sanctioned seven companies and one individual linked to the RSF. The RSF’s ability to acquire military equipment and generate finances continue to fuel the conflict in Sudan. Capital Tap Holding L.L.C. (Capital Tap Holding), based in the United Arab Emirates (UAE), has provided money and weapons to the RSF. Read more.
Venezuela-related Sanctions
- OFAC Sanctions Venezuelan Officials Supporting Nicolas Maduro’s Regime: OFAC on Jan. 10 sanctioned eight Venezuelan officials who lead key economic and security agencies enabling Nicolas Maduro’s repression and subversion of democracy in Venezuela. The individuals sanctioned, pursuant to Executive Order 13692, as amended, include the president of Petroleos de Venezuela, S.A., (PdVSA), Venezuela’s state-owned oil company, and Maduro’s Minister of Transportation and president of the Venezuelan Consortium of Aeronautical Industries and Air Services (CONVIASA), the state-owned airline. In addition, OFAC sanctioned high-level Venezuelan officials in the military and police who lead entities with roles in carrying out Maduro’s repression and human rights abuses against democratic actors. Read more.
Terrorism-related Sanctions
- OFAC Adds Individuals and Entities to SDN List: OFAC on Jan. 13 added individuals Ciro Daniel Amorim Ferreira, Noah Licul, Hendrik Wahl Muller and an entity, the Terrorgram Collective to the Specially Designated Nationals List pursuant to the Global Terrorism Sanctions Regulations, 31 C.F.R. part 594 (SDGT). Read more.
- In the same announcement, OFAC reported the removal of entities and individuals from its SDN List related to Venezuela Executive Order 13850 “Blocking Property of Additional Persons Contributing to the Situation in Venezuela” (VENEZUELA-EO13850), Narcotics Trafficking Sanctions Regulations, 31 C.F.R. part 536 (SDNT) and Foreign Narcotics Kingpin Sanctions Regulations, 31 C.F.R. part 598 (SDNTK). Read more.
Corruption and Human Rights Abuse Designations
- OFAC Sanctions Corrupt Hungarian Official: OFAC on Jan. 7 sanctioned Hungarian government official, Antal Rogan for his involvement in corruption in Hungary. Rogan orchestrated schemes designed to control several strategic sectors of the Hungarian economy and to divert proceeds from those sectors to himself and to reward loyalists from his political party. Rogan is being 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 and corruption around the world. Read more.
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