Sanctions

The Commerce Department’s Bureau of Industry and Security (BIS) is taking action to further restrict the supply of both U.S.-origin and “U.S. branded” (i.e., labeled) items to Russia and Belarus for the Kremlin’s war efforts. BIS has imposed controls on a range of items subject to the Export Administration Regulations (EAR) that did not previously require export licenses when destined for Russia.  Also imposed are similarly stringent controls on items subject to the EAR that are destined for Belarus.  Notably, both countries have been made subject to broad in-country transfer controls.

In concert with the Commerce Department measures, Treasury and the State Department targeted nearly 400 individuals and entities both in Russia and in Asia, Europe, and the Middle East—whose products and services enable Russia to sustain its war effort and evade sanctions. Treasury targets include ammunition and materiel suppliers, trust and corporate formation entities, cyber and precious metals actors, advanced procurement networks and Russia's metals and mining industry. The measures also target Russian financial technology companies that provide necessary software and IT solutions for Russia’s financial sector.

Chief of the OFAC Licensing Division, Aydin M. Akgün has joined Ferrari & Associates in Washington, DC  as Director of Licensing & Compliance. During more than two decades at OFAC, Mr. Akgün worked on sanctions programs involving Iran, Belarus, Global Magnitsky, Venezuela, and Nicaragua. 

Treasury’s Office of Foreign Assets Control (OFAC) sanctioned several companies, individuals, and vessels for their involvement in the shipment of Iranian commodities, including oil and liquefied petroleum gas (LPG), to Yemen and the United Arab Emirates (UAE) on behalf of the network of Houthi financial official Sa’id al-Jamal. 

The White House extended for 12 months Executive Order 14105 of August 9, 2023,, “Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern” (the Outbound Order). . The Order identifies three categories of national security technologies and products to be restricted in US investment in China and her territories.

Friday, Treasury’s Office of Foreign Assets Control (OFAC) is taking action against 19 individuals, 14 entities, and one aircraft pursuant to Belarus-related Executive Order (E.O.) 14038.  …

Treasury's Office of Foreign Assets Control (OFAC) is issuing Russia-related General License 99A - "Authorizing the Wind Down of Transactions and Certain Transactions Related to Debt or Equity of, or Derivative Contracts Involving, MOEX, NCC, or NSD;" and Russia-related General License 100A - "Authorizing Certain Transactions Related to Debt or Equity or the Conversion of Currencies Involving MOEX, NCC, or NSD."

Treasury’s Office of Foreign Assets Control (OFAC) is targeting five individuals and seven entities based in Iran, the People’s Republic of China (PRC), and Hong Kong that have facilitated procurements on behalf of subordinates of Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL). Those designated procure various components, including accelerometers and gyroscopes, which serve as key inputs to Iran’s ballistic missile and unmanned aerial vehicle (UAV) program. Iran’s acquisition of critical missile and UAV components continues to enable its proliferation of weapons systems to its proxies in the Middle East and to Russia.”

OFAC announced a $7,452,501 settlement with State Street Bank and Trust Company on behalf of itself and its subsidiary, Charles River Systems, Inc.  State Street agreed to settle its potential civil liability for 38 apparent violations of OFAC's Ukraine-/Russia-Related sanctions. The apparent violations involved invoices that were redated or reissued by Charles River between 2016 and 2020 for certain customers who were subject to Directive 1 of Executive Order 13662, as well as certain payments outside of the applicable debt tenor (maturity range) accepted by Charles River from these customers.

OFAC sanctioned a network of six individuals and five entities based in the People’s Republic of China (PRC), involved in the procurement of items supporting the Democratic People’s Republic of Korea’s (DPRK) ballistic missile and space programs.

All financial institutions at which Russian sovereign assets are located, and that know or should know of such assets, must provide notice of such assets to OFAC no later than August 2, 2024

The Ministry of Foreign Affairs of the People’s Republic imposed sanctions on six US defense contractors, along with five executives in retaliation for sales to Taipei. Sanctioned firms included Anduril Industries, Maritime Tactical Systems, Pacific Rim Defense, AEVEX Aerospace, LKD Aerospace, and Summit Technologies Inc.

The Treasury Department said it is targeting and designating as blocked property a dozen persons and vessels, that have played a critical role in financing the Houthis’ destabilizing regional activities as part of the network of Sa’id al-Jamal. The action includes Indonesia-based Malaysian and Singaporean national Mohammad Roslan  Bin Ahmad and People’s Republic of China-based Chinese national Zhuang Liang, who have facilitated illicit shipments and engaged in money laundering for the network.

Treasury's Office of Foreign Assets Control (OFAC) is releasing the second video in its “OFAC Basics” video series, "My Funds Are Blocked, Now What?" This video provides viewers with guidance on what it means when funds are blocked in connection with OFAC sanctions, as well as recommended steps for what to do if your funds have been blocked. 

The European Council today adopted restrictive measures targeting the Belarusian economy, extending the export ban on dual-use/advanced goods and technologies, the measures include maritime navigation goods and technologies, and luxury goods.  Also controlled are services exports, transport, and select imports from the Russian vassal state. The regulation requires that EU exporters insert in their future contract the so-called 'no-Belarus clause', through which they contractually prohibit the re-exportation to Belarus or re-exportation for use in Belarus of sensitive goods and technology, battlefield goods, firearms and ammunition.

In response to continued development of Tehran's nuclear capabilities, Secretary of State Anthony Blinken announced additional measures against Iranian petrochemical transport and trade. "Over the past month, Iran has announced steps to further expand its nuclear program in ways that have no credible peaceful purpose," said Mr. Blinken.  "We remain committed to never letting Iran obtain a nuclear weapon, and we are prepared to use all elements of national power to ensure that outcome."

Treasury’s Office of Foreign Assets Control (OFAC) Tuesday sanctioned nearly 50 entities and individuals that constitute multiple branches of a sprawling “shadow banking” network used by Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL) and Islamic Revolutionary Guard Corps (IRGC) The entities, including cover companies based in Hong Kong, the United Arab Emirates (UAE), and the Marshall Islands have been used to gain illicit access to the international financial system and process the equivalent of billions of dollars since 2020.

The European Council adopted Monday a 14th package of economic and individual restrictive measures on Russia. The package includes restrictive measures on additional 116 individuals and entities , as well as sectoral measures on Energy, Third-Country Subsidiaries and other Anti-Circumvention measures, Financial Communications Systems and Defense Industrial Base, Political Activities, Port Access for specific vessels, dual-use and commodity trade controls, as well as legal protections for sanctions compliance and intellectual property.

Treasury’s Office of Foreign Assets Control (OFAC) is designating two individuals and five entities that have facilitated weapons procurement for Ansarallah, commonly referred to as the Houthis. OFAC is also designating one individual and one company, as well as identifying one vessel, that have facilitated the shipment of commodities, the sale of which provides an important funding stream to the Houthis that aids in their weapons procurement.

Just in case you're still depending on a Russian vendor for your cybersecurity, the Commerce Department has banned Kaspersky Labs from directly or indirectly providing anti-virus software and cybersecurity products or services in the United States or to U.S. persons. The Final Determination by the Bureau of Industry and Security (BIS) is the first of its kind and is the first Final Determination issued by BIS’s Office of Information and Communications Technology and Services (OICTS).  

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