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  • OFAC issues new Ukraine-/Russia-related General Licenses authorizing additional wind-down activities

    Financial Crimes

    On May 22, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued Ukraine-/Russia-related General License 15 (GL 15) authorizing specified wind-down activities through October 23, which would be otherwise prohibited by Ukraine-Related Sanctions Regulations. Permissible activities with the designated company and its subsidiaries apply to operations, contracts, and agreements that were effective prior to April 6. OFAC further stated that, while funds blocked prior to May 22 remain blocked, GL 15 permits the use of these blocked funds for specified maintenance and wind-down activities.

    The same day, OFAC also issued Ukraine-/Russia-related General License 12C (GL 12C) to replace and supersede General License 12B (GL 12B) in its entirety. (See previous InfoBytes coverage on GL 12B here.) GL 12C, which incorporates exemptions permitted under GL 15, authorizes wind-down activities “originating and intermediary U.S. financial institutions to process funds transfers that they would otherwise block to an account held by a blocked U.S. person at a U.S. financial institution,” and allows the release of “such funds for authorized maintenance and wind-down purposes.” GL 12C is effective May 22.

    OFAC also released six new FAQs and published updated FAQs related to these general licenses.

    Visit here for additional InfoBytes coverage on Ukraine/Russian sanctions.

    Financial Crimes OFAC Department of Treasury Ukraine Russia Sanctions International

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  • President Trump issues new Executive Order prohibiting the purchase of debt from the Venezuelan government

    Financial Crimes

    On May 21, President Trump issued an Executive Order (E.O.) prohibiting U.S. companies or individuals from buying debt or accounts receivable from the Venezuelan government “in light of the recent activities of the Maduro regime, including endemic economic mismanagement and public corruption at the expense of the Venezuelan people and their prosperity.” The sanctions specifically prohibit transactions related to the following: (i) “the purchase of debt owed to the Venezualan government, including accounts receivable;” (ii) debt pledged as collateral after May 21, including accounts receivable; and (iii) “the sale, transfer, assignment, or pledging as collateral by the Government of Venezuela of any equity interest in any entity in which the Government of Venezuela has a 50 percent or greater ownership interest.”

    The E.O., issued in conjunction with E.O. 13692, follows two prior E.O.s, which also targeted the Maduro regime—E.O. 13827, which prohibits U.S. persons from engaging in transactions that involve digital currency issued by, for, or on behalf of the Venezuelan government, and E.O. 13808, which prohibits transactions related to new debt, bonds, and dividend payments in conjunction with the Venezuelan government and the state-owned oil company. (See previous InfoBytes coverage here and here.). The E.O. took effect on May 21 at 12:30 p.m. EDT.

    See here for continuing InfoBytes coverage of actions related to Venezuela.

    Financial Crimes OFAC Department of Treasury Executive Order Trump Venezuela Sanctions International Cryptocurrency

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  • OFAC further expands Iranian sanctions, includes Hizballah-associated individuals

    Financial Crimes

    On May 17, U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) identified two Hizballah-associated individuals for their alleged role in financing terrorist networks, in addition to five companies owned or controlled by one of the designated individuals, as “Specially Designated Global Terrorists.” According to OFAC, the sanctions were issued pursuant to Executive Order 13224 (E.O. 13224), and designated individuals who had previously worked with the Central Bank of Iran, which was “recently identified as being complicit in facilitating the [Islamic Revolutionary Guard Corps-Qods Force’s (IRGC-QF)] access to hundreds of millions of dollars in U.S. currency, to expand banking access between Iran and Lebanon.” As covered earlier in InfoBytes, on May 15 OFAC sanctioned the governor and a senior official of the Central Bank of Iran for allegedly funneling millions of dollars on behalf of the IRGC-QF to Hizballah. The May 17 actions are designed to “further restrict Hizballah’s access to the U.S. financial system and the Iranian regime’s network of regional proxy groups.” As a result, all assets belonging to the identified individuals and entities subject to U.S. jurisdiction must be blocked and reported to OFAC, and U.S. persons are generally prohibited from dealing with them.

    Separately, on May 22, OFAC announced that five Iranian individuals who allegedly provided ballistic missile-related technical expertise on behalf of the IRGC-QF have also been sanctioned pursuant to E.O. 13224. In addition to freezing assets subject to U.S. jurisdiction and prohibiting U.S. persons from engaging in transactions with the individuals, “foreign financial institutions that knowingly facilitate significant transactions for, or persons that provide material or certain other support to, the individuals and entities designated [] risk exposure to sanctions that could sever their access to the U.S. financial system or block their property and interests in property under U.S. jurisdiction.”

    See here for continuing InfoBytes coverage of actions related to Iran.

    Financial Crimes OFAC Sanctions Department of Treasury Iran International

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  • OFAC adds additional Venezuelan government officials to Specially Designated Nationals List

    Financial Crimes

    On May 18, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) made additions to the Specially Designated Nationals List pursuant to Executive Order 13692. OFAC’s additions to the list include four current or former Venezuelan government officials identified as persons who have “exploit[ed] their official positions to engage in narcotics trafficking, money laundering, embezzlement of state funds, and other corrupt activities.” OFAC additionally blocked three companies and 14 properties located in Florida and New York owned by one of the recently added officials. As a result, all assets belonging to the identified individuals and entities subject to U.S. jurisdiction are blocked and must be reported to OFAC, and U.S. persons are generally prohibited from dealing with them.

    See here for continuing InfoBytes coverage of actions related to Venezuela.

    Financial Crimes OFAC Sanctions Venezuela Department of Treasury International

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  • Macau real estate developer sentenced for bribing UN officials

    Financial Crimes

    On May 11, Judge Vernon S. Broderick of the SDNY sentenced a Macau real estate developer to 48 months in prison and ordered him to pay a $1 million fine, $302,977 in restitution, and forfeiture of $1.5 million.  In July 2017, a jury convicted the developer of two counts of violating the FCPA, one count of paying bribes and gratuities, one count of money laundering, and two counts of conspiracy.  The conduct centered on the developer’s role in bribing UN officials in order to build a new multi-billion dollar conference center in Macau.   

    Five other defendants have been charged; four have pleaded guilty to various charges, and one passed away and the charges against him were dismissed.  Of the guilty pleas, two are awaiting sentencing.  The other two received sentences of seven months (conspiracy to defraud the United States) and 20 months (bribery).

    Prior Scorecard coverage of this matter can be viewed here.

    Financial Crimes International FCPA Bribery

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  • OFAC sanctions Iranian bank officials, Iraqi bank, and others for moving millions of dollars to Hizballah

    Financial Crimes

    On May 15, U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced it was imposing sanctions on the governor and a senior official of the Central Bank of Iran, an Iraqi bank and its chairman, and a key Hizballah official, for allegedly funneling millions of dollars on behalf of the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) to Hizballah. Pursuant to Executive Order 13224, which “provides a means by which to disrupt the financial support network for terrorists and terrorist organizations by authorizing the U.S. government to designate and block the assets of foreign individuals and entities that commit, or pose a significant risk of committing, acts of terrorism,” the individuals and entities were designated as Specially Designated Global Terrorists. The actions, which follow a May 10 action taken against individuals and entities who materially assisted in the conversion of millions of U.S. dollars to fund IRGC-QF’s malignant activities, “seek to stifle Iran’s ability to abuse the U.S. and regional financial systems.”

    However, OFAC clarified that sanctions on the officials of the Central Bank of Iran do not extend to the bank itself. Following President Trump's decision to cease participation by the U.S. government in the Joint Comprehensive Plan of Action, sanctions on the bank will be re-imposed August 7, and on November 5, additional sanctions will be re-imposed on persons knowingly engaging in certain significant transactions with the Central Bank of Iran.

    Visit here for additional InfoBytes coverage on Iranian sanctions.

    Financial Crimes OFAC Department of Treasury Sanctions Iran Iraq International

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  • OFAC adds Iranians to Specially Designated Nationals List

    Financial Crimes

    On May 10, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) made additions to the Specially Designated Nationals List under the Iranian Financial Sanctions Regulations and Global Terrorism Sanctions Regulations. OFAC’s additions to the designations identify nine individuals and entities that materially assisted in converting millions of U.S. dollars to fund the Islamic Revolutionary Guard Corps-Qods Force’s malignant activities. As a result, all assets belonging to the identified individuals and entities subject to U.S. jurisdiction are blocked and must be reported to OFAC, and U.S. persons are generally prohibited from dealing with them.

    Financial Crimes OFAC Department of Treasury International Iran Sanctions

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  • Brother of Honduran government official indicated for laundering bribes in New Orleans

    Financial Crimes

    On May 1, the Department of Justice announced the indictment of a Honduran national for trying to launder more than $1.3 million in bribes that had been paid to his brother, the former Executive Director of the Honduran Institute of Social Security. The bribes had been paid by two Honduran businessmen for the benefit of the Executive Director. The indictment alleges that he conspired with his brother to launder the funds through international wire transfers and the purchase of real estate in the New Orleans area. The indictment further alleges that he also used his brother’s high-ranking position to profit from lucrative Honduran government contracts and that he impeded an official proceeding by lying to the U.S. government about the source of the funds. He was arrested on the same day the indictment was announced.

     

    Financial Crimes FCPA International

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  • OFAC adds Venezuelans to Specially Designated Nationals List

    Financial Crimes

    On May 7, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) made additions to the Specially Designated Nationals List under the Foreign Narcotics Kingpin Designation Act. OFAC’s additions to the list include a former Venezuelan financial intelligence service official, two of his aides, and 20 companies located in Venezuela and Panama, owned or controlled by the three individuals. The designations identify persons who have materially assisted in, or provided financial or technological support for or to, the former official’s international narcotics trafficking activities, which include the laundering of narcotics proceeds and other illicit funds. As a result, all assets belonging to the identified individuals and entities subject to U.S. jurisdiction are blocked and must be reported to OFAC, and U.S. persons are generally prohibited from dealing with them.

    See here for continuing InfoBytes coverage of Venezuelan actions.

    Financial Crimes OFAC Department of Treasury International Venezuela Sanctions

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  • OFAC issues new Ukraine-/Russia-related General Licenses and FAQs

    Financial Crimes

    On May 1, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued Ukraine-/Russia-related General License 12B (GL 12B) authorizing specified wind-down activities, which would be otherwise prohibited by Ukraine-related Sanctions Regulations, through June 5. According to a Treasury announcement, GL 12B—which replaces and supersedes General License 12A in its entirely—permits “originating and intermediary U.S. financial institutions to process funds transfers that they would otherwise block to an account held by a blocked U.S. person at a U.S. financial institution,” and allows the release of “such funds for authorized maintenance and wind-down purposes.”

    The same day, OFAC also issued Ukraine-/Russia-related General License 13A (GL 13A) to replace and supersede General License 13 (GL 13) in its entirety. (See previous InfoBytes coverage on GL 13 here.) GL 13A authorizes certain divestiture transactions with specified blocked persons to a non-U.S. person, and allows the facilitation of transfers of debt, equity, or other holdings involving listed blocked persons, including entities owned 50 percent or more and issued by the named persons. GL 13A is effective through June 6.

    OFAC also released three new FAQs and published updated FAQs related to these general licenses.

    Visit here for additional InfoBytes coverage on Ukraine/Russian sanctions.

    Financial Crimes OFAC Department of Treasury Department of State International Ukraine Russia Sanctions

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