The Office of Foreign Assets Control announced the following sanctions action in the last two weeks.
Enforcement Action
OFAC announces $1.72 million settlement with IMG Academy: OFAC announced a $1,720,000 settlement with IMG Academy, LLC for 89 apparent violations of U.S. counternarcotics sanctions, after the school entered yearly tuition agreements and processed payments from Specially Designated Nationals (SDNs) tied to a Mexico‑based drug cartel between 2019 and 2025. OFAC assessed the conduct as non‑egregious and not voluntarily disclosed, resulting in the agreed settlement amount. Read more.
Russia-related Sanctions
Update to OFAC’s SDN List: OFAC has updated the entry for Limited Liability Company Investment Consultant Elbrus Capital, revising its listed name and address. The entity—previously recorded at Nab. Presnenskaya D. 10, Floor 27, KOM. 11V, Moscow 123112, Russia—now appears as Limited Liability Company Investment Consultant Elbrus Capital (a.k.a. Capella Capital Limited Liability Company) with an updated address at 3/10 Elektricheskiy pereulok, building 1, office 1N/6, Presnenskiy District, Moscow 123557, Russia. All associated identifiers, including its tax ID, registration number, and secondary‑sanctions risk under Executive Order 14024, remain unchanged.
Foreign Terrorist Organization Sanctions
OFAC sanctions CJNG-linked timeshare fraud network: On Feb. 19, OFAC sanctioned a timeshare fraud network led by the OFAC-designated Cartel de Jalisco Nueva Generación (CJNG), targeting Kovay Gardens—a Mexican timeshare resort—along with five individuals and 17 companies tied to the scheme. Many of the sanctioned actors operate in or near Puerto Vallarta, a CJNG stronghold, where the network has defrauded vulnerable older Americans of significant savings. Read more.
Additionally, OFAC issued Counter Terrorism General License 34, which temporarily authorizes limited wind‑down transactions involving Kovay Gardens until March 21, 2026, while maintaining all blocking requirements.
OFAC targets key Hizballah revenue and procurement networks: On Feb. 10, OFAC sanctioned Lebanon-based gold exchange company Jood SARL, which operates under Hizballah’s U.S.-designated Al-Qard Al-Hassan and helps convert the group’s gold reserves into liquid funds. OFAC also designated an international procurement and shipping network run by Hizballah financiers across the region, including Iran, aimed at sustaining the group’s financing and operations. Treasury emphasized that these actions are part of ongoing efforts to cut Hizballah off from the global financial system and counter its destabilizing activities in the Middle East. Read more.
Sudan-related Sanctions
OFAC sanctions RSF commanders for atrocities in El‑Fasher: On Feb. 19, OFAC sanctioned three commanders of Sudan’s Rapid Support Forces (RSF) for leading the group’s 18‑month siege and eventual capture of El‑Fasher in Sudan, where RSF fighters carried out a brutal campaign of ethnic killings, torture, starvation, and violence. These sanctions come amid extensive evidence that, since Sudan’s civil war began in April 2023, the RSF and allied militias have committed widespread atrocities amounting to war crimes, crimes against humanity, and genocide. Read more.
Venezuela-related Sanctions
OFAC expands authorizations for Venezuela’s energy sector: In mid‑February, OFAC issued General License 49 and General License 50 authorizing negotiations of contingent contracts and certain oil and gas sector transactions in Venezuela. Days later, OFAC released amended General License 50A, refining permitted oil and gas activities for specified entities, and published two new FAQs (1236 and 1237) to provide additional guidance on updated Venezuela authorizations.
