Sanctions

Treasury is imposing sanctions on three Nicaragua-based entities, the Training Center of the Russian Ministry of Internal Affairs in Managua (RTC); Compania Minera Internacional, S.A. (COMINTSA); and Capital Mining Investment Nicaragua, S.A. The RTC is a Nicaragua-based subdivision of the Government of the Russian Federation’s (GOR) Ministry of Internal Affairs, and is a "key actor in the Nicaraguan regime’s repression of civil society and unjust detention and imprisonment of individuals for expressing dissent, or otherwise peacefully exercising their human rights and fundamental freedoms," according to the OFAC statement. The designations of COMINTSA and Capital Mining target government-affiliated gold companies generating revenue for the Ortega-Murillo regime. Gold is Nicaragua’s top commodity export.

Treasury’s Office of Foreign Assets Control (OFAC) designated one Russian individual and three Russia-based companies involved in an attempted sanctions evasion scheme in which an "opaque and complex supposed divestment" could have unfrozen more than $1.5 billion worth of shares belonging to U.S.-designated Russian oligarch Oleg Deripaska. The transactions was part of a scheme to repatriate some of Austria's  Raiffeisen Bank capital stranded in Russia.

The Commerce Department’s Bureau of Industry and Security added 37 entities – mostly based in China – to the Entity List under the Export Administration Regulations.  BIS said the action, announced Thursday, reflects the Administration’s commitment to safeguarding US national security and foreign policy interests.

Etablissements Maurel & Prom S.A. (Paris:MAU) (“M&P”, “the Group”) announces it has received a specific license it had applied for on 1 September 2023 from the U.S. …

On Wednesday 8 May 2024, the UK government hosted a senior US government delegation for the second US-UK Strategic Sanctions Dialogue. The United States and the United Kingdom reaffirmed that sanctions and export controls are essential tools of national security policy. The delegations discussed the uses of targeted, coordinated sanctions and export control measures to deter and disrupt malign activity and to defend international norms.

OFAC has extended the General License 8M issued last November through November 2024. The GL authorizes certain disbursements necessary for the maintenance and security of operations, but not the drilling, lifting or transportation of petroleum for PDVSA, the Venezuelan state-owned oil company.

OFAC announced it has removed Russo-Maltese executive jet operator Emperor Aviation and its fleet from the list of Specially Designated Nationals.   No explanation was provided for the change. The company and aircraft had been added to OFAC’s Specially Designated Nationals (SDN) list for conducting travel for the family of Suleiman Kerimov.

OFAC has deployed its new Sanctions List Service (SLS).  SLS is now the primary application OFAC will use to deliver sanctions list files and data to the public. OFAC's Sanctions List …

May 1 the Treasury Department issued sanctions targeting Russia’s military-industrial base and chemical and biological weapons programs,  as well as companies and individuals in third countries that help Russia acquire key inputs for weapons or defense-related production. The action includes nearly 60 targets located in Azerbaijan, Belgium, the PRC, Russia, Slovakia, Türkiye, and the United Arab Emirates (UAE).  

On 1 May, the U.K. Office of Financial Sanctions Implementation (OFSI) introduced Frequently Asked Questions (FAQs), a new form of additional guidance aimed at providing technical support to industry partners and the public. 

Included among the munitions and TikTok drama, the foreign aid package signed last week has material changes for the sanctions compliance practitioner. Front and center for sanctions practitioners is the extension of the statute of limitations for sanctions (SOL) violations.

Treasury’s Office of Foreign Assets Control is sanctioning over one dozen entities, individuals, and vessels that have played a central role in facilitating and financing the clandestine sale …

Tuesday the Treasury Department announced sanctions on Iranian cyber actors and representatives of Islamist extremists responsible for taking hostage U.S. nationals.

Treasury's Office of Foreign Assets Control (OFAC) announced a settlement with SCG Plastics Co., Ltd., part of a multinational enterprise headquartered in Bangkok, Thailand. SCG Plastics has agreed to pay $20,000,000 to settle its potential civil liability for 467 apparent violations of OFAC sanctions on Iran.

Treasury’s Office of Foreign Assets Control (OFAC) is taking sweeping actions against several actors involved in Iran’s unmanned aerial vehicle (UAV) program, suppliers and customers of one of Iran’s largest steel producers, and Iranian automobile companies with connections to U.S.-designated entities Islamic Revolutionary Guard Corps (IRGC) and the Ministry of Defense and Armed Forces Logistics (MODAFL).

The State Departemnt designated four entities pursuant to Executive Order 13382, which targets proliferators of weapons of mass destruction and their means of delivery. These entities – three based in the People’s Republic of China and one in Belarus – have supplied missile‐applicable items to Pakistan’s ballistic missile programs, including its long-range missile program.

In an effort to further isolate the Russian and Belarus military-industrial complex,  the U.S. Treasury’s Office of Foreign Assets Control (OFAC) is designating 12 entities and 10 individuals pursuant to Executive Order (E.O.) 14038,  The individuals and entities OFAC is targeting include six revenue-generating state-owned enterprises (SOEs) and one entity and five individuals involved in facilitating transactions for a U.S.-designated major Belarusian defense sector enterprise.

The Administration is calling on Congress to give it additional tools to prevent terrorist groups and other malign actors from using crypto-currencies to circumvent US sanctions. Treasury Deputy Secretary Wally Adeyemo told the Senate Banking Committee last week that the Administration needs “additional tools to protect the American people.”

In a joint action with UK officials, the Treasury Department issued two new prohibitions to disrupt the revenue that Russia earns from its export of aluminum, copper, and nickel.  This new action prohibits the import of Russian-origin aluminum, copper, and nickel into the US and UK, and limits the use of Russian-origin aluminum, copper, and nickel on global metal exchanges and in over-the-counter derivatives trading.

Commerce Department’s Bureau of Industry and Security (BIS) added 11 entities to the Entity List .Five of the eleven entities are Russian and PRC entities were added for actions related to unmanned aerial vehicles (UAVs). Of these, four are part of a procurement network for components for UAV applications. These components are used to develop and produce Shahed-series UAVs which have been used by Iran to attack oil tankers in the Middle East and by Russia in Ukraine.

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