Skip to main content
Menu Icon Menu Icon
Close

InfoBytes Blog

Financial Services Law Insights and Observations
Section Content

Upcoming Events

Filter

Subscribe to our InfoBytes Blog weekly newsletter and other publications for news affecting the financial services industry.

  • OFAC revokes JCPOA-related General Licenses

    Financial Crimes

    On June 27, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued an announcement revoking Iran-related General Licenses H and I (GL-H and GL-I) following President Trump’s May 8 withdrawal from the Joint Comprehensive Plan of Action. In conjunction with these changes, OFAC amended the Iranian Transactions and Sanctions Regulations to authorize certain wind-down activities through August 6 (GL-I) and November 4 (GL-H) related to, among other things, letters of credit and brokering services. In addition OFAC released updated FAQs related to the May 8 re-imposition of nuclear-related sanctions.

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

    Financial Crimes OFAC Iran Sanctions International

    Share page with AddThis
  • OFAC adds Iranians to Specially Designated Nationals List

    Financial Crimes

    On May 30, 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 were found to have (i) committed serious human rights abuses on behalf of the Government of Iran; (ii) operated technology that facilitates monitoring that could assist in serious human rights abuses by the Government of Iran; or (iii) engaged, or acting on behalf of someone engaged, in censorship activities limiting the freedom of expression or assembly of citizens in Iran. 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 engaging in transactions with them.

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

    Financial Crimes OFAC Department of Treasury International Iran Sanctions

    Share page with AddThis
  • 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

    Share page with AddThis
  • 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

    Share page with AddThis
  • 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

    Share page with AddThis
  • OFAC sanctions Iranian nationals for malicious cyberattacks

    Financial Crimes

    On March 23, the Treasury Department’s Office of Foreign Assets Control (OFAC), in coordination with the DOJ, imposed additional sanctions on an Iranian entity and 10 Iranian nationals, pursuant to Executive Order 13694, for conducting malicious cyberattacks against hundreds of U.S. and third-country universities for private financial gain. Nine of the identified individuals are connected to the Mabna Institute and are accused of misappropriating “economic resources or personal identifiers” to aid Iran’s Islamic Revolutionary Guard Corps. Pursuant to these sanctions, all property or interests in property of the designated persons within U.S. jurisdiction are blocked, and U.S. persons are “generally prohibited” from participating in transactions with these individuals and entities. Additionally, as reported in a DOJ press release, the nine Iranians have also been indicted for engaging in malicious cyber-enabled activities. A tenth Iranian national was sanctioned for engaging in cyber-related actions targeting a U.S. media company.

    Visit here for additional InfoBytes coverage on Iranian sanctions.

    Financial Crimes OFAC Sanctions International Department of Treasury Privacy/Cyber Risk & Data Security Iran

    Share page with AddThis
  • OFAC expands Venezuelan and Iranian sanctions

    Financial Crimes

    On January 5, the Treasury Department’s Office of Foreign Assets Control (OFAC) imposed additional sanctions against four current or former officials of the Venezuelan government. The designations, issued pursuant to Executive Order 13692, identify officials who are “associated with corruption and repression in Venezuela” and have “forsaken the professional republican mission of the military institution, which . . . is to be ‘with no political orientation … and in no case at the service of any person or political partisanship.’” All assets belonging to the identified individuals subject to U.S. jurisdiction are frozen, and U.S. persons are generally prohibited from dealing with them. See here for previous InfoBytes coverage of Venezuelan sanctions.

    Separately on January 4, OFAC designated five Iranian entities, pursuant to Executive Order 13382 (E.O. 13382), for their ties to Iran’s ballistic missile program. The five entities identified in the designation are either owned or controlled by an Iranian group that is “responsible for the development and production of Iran's solid-propellant ballistic missiles, is listed in the Annex to E.O. 13382 and is currently sanctioned by the U.S., UN, and EU.” In addition to freezing assets subject to U.S. jurisdiction and prohibiting U.S. persons from engaging in transactions with the entities, “foreign financial institutions that knowingly facilitate significant transactions for, or persons that provide material or certain other support to, the entities designated today 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 previous InfoBytes coverage of Iranian sanctions.

    Financial Crimes Department of Treasury OFAC Sanctions International Executive Order Venezuela Iran

    Share page with AddThis
  • OFAC Penalizes Dental Supply Company for Violations of the Iranian Transactions and Sanctions Regulations

    Financial Crimes

    The U.S. Treasury Department’s Office of Foreign Asset Control (OFAC) announced that it entered into a $1.2 million settlement with a U.S. dental supply company for alleged violations of the Iranian Transactions and Sanctions Regulations (ITSR). According to the December 6 announcement, between November 2009 and July 2012, two of the company’s subsidiaries exported 37 shipments of dental supplies to distributors in other countries with “knowledge or reason to know that the goods were ultimately destined for Iran.” OFAC determined that the alleged violations were non-egregious.

    In determining the settlement amount, OFAC considered multiple factors, including that (i) the subsidiaries acted willfully in violation of the ITSR because employees concealed their knowledge that the goods were destined for Iran; (ii) subsidiary supervisory personnel actively concealed their awareness of the apparent violations from their U.S. parent company; and (iii) the U.S. company is “commercially sophisticated” with knowledge of OFAC’s regulations. OFAC also considered numerous mitigating factors, including (i) the fact that the U.S. company has not received a penalty from OFAC in the previous five years; (ii) the harm to the ITSR program was limited; and (iii) the U.S. company cooperated with the investigation and took remedial steps. 

    Financial Crimes OFAC Sanctions Settlement Department of Treasury Iran

    Share page with AddThis
  • OFAC Imposes Additional Iranian Sanctions, List Includes Entities Involved in DDoS Attacks Against U.S. Financial Institutions

    Financial Crimes

    On September 14, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced it was imposing sanctions on 11 entities and individuals for supporting designated Iranian actors or for conducting malicious cyberattacks, including engaging in a series of distributed denial of service (DDoS) attacks against approximately 46 U.S. financial institutions. As reported in an indictment delivered by a federal grand jury in the Southern District of New York (see March 24, 2016 DOJ press release), the DDoS attacks—allegedly conducted by seven Iranian individuals between December 2011 and mid-2013—denied customers access to online bank accounts and collectively cost the affected financial institutions “tens of millions of dollars in remediation costs as they worked to neutralize and mitigate the attacks on their [computer] servers.” During a DDoS attack, a “malicious actor” gains remote control of a server through the installation of malicious software. Once compromised, the “malicious actor” can collect hundreds or thousands of these compromised devices (collectively known as a “botnet”), and, once control is achieved, will “direct the computers or servers comprising the botnet to carry out computer network attack[s] and computer network exploitation activity.” Three of the seven sanctioned individuals worked for a company that was added to OFAC’s updated SDN list on September 14 and oversaw a network of compromised computers that powered DDoS attacks. The other four individuals operated a second DDoS botnet on behalf of a different company listed on OFAC’s non-SDN list. Both Iranian-based private computer security companies perform work on behalf of the Iranian Government, including Iran’s Islamic Revolutionary Guard Corps. Pursuant to E.O. 13694, U.S. persons are prohibited from dealing with the designated entities and individuals, and “foreign financial institutions that facilitate significant transactions for, or persons that provide material or certain other support to, the entities and individuals designated today 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.”

    In addition, pursuant to E.O. 13382, OFAC sanctioned an Iranian-based engineering company for engaging in activities related to Iran’s ballistic missile program, which include providing “ financial, material, technological, or other support for, or goods or services in support of, the [Islamic Revolutionary Guard Corps].” Two Ukrainian-based companies were also sanctioned pursuant to E.O. 13224 for assisting previously sanctioned Iranian and Iraqi airlines in obtaining U.S.-origin aircraft, as well as crew and services.

    Financial Crimes Sanctions Department of Treasury OFAC DOJ Indictment Privacy/Cyber Risk & Data Security

    Share page with AddThis
  • OFAC Settles Alleged Iran Sanction Violations with Singapore-Based Oilfield Services Company

    Financial Crimes

    On August 24, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced that it had reached a $415,350 settlement with a Singaporean oilfield services company for an alleged 55 violations of Iran sanctions regulations. OFAC asserted that the company “exported or attempted to export 55 orders of oil rig supplies from the [U.S.] to Singapore and the United Arab Emirates, and then re-exported or attempted to re-export these supplies to four separate oil rigs located in Iranian territorial waters” from approximately October 2011 through February 2013. OFAC alleged that each instance of this conduct, which the company did not voluntarily self-disclose, violated OFAC’s Iranian Transactions and Sanctions Regulations. Had the company not settled, OFAC determined that civil monetary penalties ranged from approximately $923,000 to $13.75 million. In establishing the penalty, OFAC considered that the company: (i) failed to act with an appropriate level of caution by exporting goods to oil rigs located in Iranian territorial waters; (ii) aided the development of Iran's energy resources; (iii) “is a large, sophisticated company with 14 offshore drilling rigs doing business throughout the world;” and (iv) “did not have an OFAC compliance program in place at the time of the transactions.” As for mitigating factors, OFAC determined that: (i) the company has no prior sanctions history with OFAC; (ii) the company took remedial action by implementing an OFAC compliance program; and (iii) the company cooperated with the investigation and entered into a tolling agreement with OFAC.

    Financial Crimes OFAC Sanctions Department of Treasury

    Share page with AddThis

Pages