The Office of Foreign Assets Control announced the following sanctions action last week.
Enforcement Action
ShapeShift AG settles with OFAC for $750,000 over sanctions violations: On Sept. 22 OFAC announced a $750,000 settlement with ShapeShift AG, a now-defunct digital asset exchange formerly headquartered in Denver, Colorado, for apparent violations of multiple U.S. sanctions programs. Between December 2016 and October 2018, ShapeShift processed digital asset transactions involving users in Cuba, Iran, Sudan, and Syria, in violation of U.S. sanctions. The violations were deemed non-egregious and not voluntarily self-disclosed. ShapeShift ceased operations in 2021 and no longer offers digital asset services. Read more.
Syria-related Sanctions
OFAC final rule: Syria sanctions regulations renamed and updated: On Sept. 25, OFAC issued a final rule amending the Syria-Related Sanctions Regulations (31 CFR Part 569). The amendments include:
- Renaming the regulations to the Promoting Accountability for Assad and Regional Stabilization Sanctions Regulations.
- Implementing two new Syria-related Executive Orders:
- E.O. 14142 (issued Jan. 15, 2025): Updates sanctions to reflect evolving conditions in Syria.
- E.O. 14312 (issued June 30, 2025): Revokes certain Syria sanctions while maintaining restrictions on human rights abusers, terrorist affiliates, and destabilizing actors.
These changes take effect upon publication in the Federal Register on September 25, 2025. OFAC has also updated its Specially Designated Nationals and Blocked Persons (SDN) List accordingly. Read more.
North Korea-related Sanctions
OFAC sanctions DPRK arms network supplying Burmese military: On Sept. 25, OFAC sanctioned five individuals and one entity for facilitating weapons sales that generate illicit revenue for the Democratic People’s Republic of Korea (DPRK) and its weapons of mass destruction (WMD) and ballistic missile programs.
Key designations include:
- Royal Shune Lei Company Limited, a Burmese arms procurement firm that brokered weapons deals with DPRK’s Korea Mining Development Trading Corporation (KOMID)
- Kyaw Thu Myo Myint, Royal Shune Lei employee
- Tin Myo Aung, CEO of Royal Shune Lei
- Aung Ko Ko Oo, director of Royal Shune Lei
- Kim Yong Ju, deputy KOMID representative in Beijing
- Nam Chol Ung, an intelligence officer and representative of U.S.-designated DPRK Reconnaissance General Bureau (RGB).
These individuals coordinated the sale of aerial bomb guidance kits and other military equipment to the Burmese military regime. The designations were made under Executive Orders 13551, 13687, and 14014. Read more.
Corruption and Human Rights Abuse Designations
OFAC sanctions Brazilian holding company tied to Supreme Court Justice: On Sept. 22, the U.S. Department of the Treasury’s Office of Foreign Assets Control sanctioned Lex Instituto de Estudos Juridicos LTDA (Lex Institute), a Brazilian holding company owned and controlled by Alexandre de Moraes, a sitting justice on Brazil’s Supreme Federal Court. OFAC also designated Viviane Barci de Moraes, de Moraes’ wife and managing partner of the Lex Institute.
These actions follow OFAC’s July 30 designation of de Moraes under Executive Order 13818, which implements the Global Magnitsky Human Rights Accountability Act. De Moraes was cited for using his judicial authority to authorize arbitrary detentions and suppress freedom of expression, including actions against former President Jair Bolsonaro. Read more.
Counter-narcotics-related Sanctions
OFAC sanctions Indian nationals and online pharmacy for fentanyl trafficking: On Sept. 24, OFAC sanctioned two Indian nationals—Sadiq Abbas Habib Sayyed and Khizar Mohammad Iqbal Shaikh—for trafficking counterfeit prescription pills laced with fentanyl and other illicit drugs to victims across the United States.
OFAC also designated KS International Traders (a.k.a. “KS Pharmacy”), an India-based online pharmacy owned by Shaikh, for its role in the operation. The individuals and entity were sanctioned under Executive Order 14059, which targets the international proliferation of illicit drugs. Read more.
