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OFAC sanctions Iranian ship captains for delivering gasoline to Venezuela
On June 24, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced that the captains of five Iranian U.S.-sanctioned tankers have been added to the Specially Designated National and Blocked Persons List (SDN List) for allegedly delivering gasoline and gasoline components to Venezuela. Treasury emphasized it “will target anyone who supports Iranian attempts to evade United States sanctions,” and stated it will use its authority to disrupt the Iranian regime’s support to Venezuela. As a result of the sanctions, “all property and interests in property of these targets that are in the United States or in the possession or control of U.S. persons is blocked and must be reported to OFAC.” OFAC further noted that its regulations “generally prohibit all dealings by U.S. persons or within the United States (including transactions transiting the United States) that involve any property or interests in property of blocked or designated persons,” and warned foreign financial institutions that knowingly facilitating significant transactions for any of the designated individuals or entities may subject them to U.S. sanctions.
OFAC sanctions four Iranian metal companies
On June 25, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions against four steel, aluminum, and iron companies for being directly or indirectly owned or controlled by Iran’s largest steel manufacturer, which was previously designated for operating in Iran’s steel sector and sanctioned by the Terrorist Financing Targeting Center for taking part in Iran’s terror support network. OFAC’s designations also target four foreign sales agents for being owned or controlled by the designated steel manufacturer, which, combined, “generated tens of millions of dollars annually” and provided “significant contributions to the billions of dollars generated overall by Iran’s steel, aluminum, copper, and iron sectors.” OFAC’s actions are taken pursuant to Executive Order 13871 (covered by InfoBytes here), which authorizes the imposition of sanctions on persons determined to operate in Iran’s iron, steel, aluminum, and copper sectors, which OFAC identified as providing “funding and support for the proliferation of weapons of mass destruction, terrorist groups and networks, campaigns of regional aggression, and military expansion.”
As a result of the sanctions, “all property and interests in property of these persons that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC.” OFAC further noted that its regulations “generally prohibit all dealings by U.S. persons or within (or transiting) the United States that involve any property or interests in property of blocked or designated persons, unless licensed or exempt,” and warned foreign financial institutions that knowingly facilitating significant transactions to the designated entities may subject them to U.S. correspondent account or payable-through sanctions.
OFAC sanctions network for supporting Maduro regime, blocks two vessels
On June 18, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions against three individuals and eight foreign entities for allegedly engaging in activities in or associated with a network attempting to evade U.S. sanctions on Venezuela’s oil sector. Two vessels owned by two of the designated entities were also identified as blocked property pursuant to Executive Order 13850. OFAC noted that the identified persons participated in a scheme involving involved Venezuela’s state-owned oil company, Petroleos de Venezuela, S.A. (PdVSA), in order to benefit “the illegitimate regime of President Maduro.” Both PdVSA and Maduro were previously designated by OFAC (covered by InfoBytes here and here), and OFAC warned that persons who facilitate activity with designated persons “risk losing access to the U.S. financial system.” As a result, all property and interests in property belonging to the identified individuals and entities subject to U.S. jurisdiction are blocked, and “any entities that are owned, directly or indirectly, 50 percent or more by the designated entities, are also blocked.” U.S. persons are generally prohibited from dealing with any property or interests in property of blocked or designated persons.
OFAC sanctions Nigerian nationals involved in business email compromise and romance fraud scheme
On June 16, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced a coordinated action with the DOJ against six Nigerian nationals who allegedly conducted a business email compromise (BEC) scheme and engaged in romance fraud to steal more than $6 million from U.S. businesses and individuals. The designated individuals’ actions included, among other things, allegedly impersonating businesses executives to request and receive wire transfers from legitimate business accounts, and using manipulative tactics to gain access to usernames, passwords, and bank accounts. OFAC designated the individuals pursuant to Executive Order 13694, which “targets malicious cyber-enabled activities, including those related to the significant misappropriation of funds or economic resources for private financial gain.” As a result, all property and interests in property belonging to the designated individuals subject to U.S. jurisdiction are blocked, and “U.S. persons generally are prohibited from dealing with them.”
OFAC also provided additional information regarding BEC scams and romance fraud and referred to the Financial Crimes Enforcement Network’s July 2019 advisory, which addresses efforts designed to restrict and impede BEC scammers and other illicit actors who profit from email compromise fraud schemes (covered by InfoBytes here).
OFAC sanctions investors supporting Syrian government
On June 17, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions against 24 individuals and entities for providing significant investment support to the Syrian government. According to OFAC, the designations include Treasury’s “first implementation of sanctions pursuant to the Caesar Syria Civilian Protection Act of 2019,” and involve actions taken against a holding company, a private sector investment venture, and luxury tourism developments. Concurrent with OFAC’s sanctions, the U.S. State Department also designated 15 persons, including President Bashar al-Assad and his wife, pursuant to Executive Order 13984, which focuses on persons identified as “obstructing, disrupting, or preventing a ceasefire or a political solution to the Syrian conflict.” As a result, all property and interests in property belonging to the designated persons and subject to U.S. jurisdiction are blocked and must be reported to OFAC. OFAC further noted that its regulations “generally prohibit all dealings by U.S. persons or those within (or transiting) the United States that involve any property or interests in property of designated persons,” and warned non-U.S. persons that engage in transactions with the designated persons may expose themselves to designation. OFAC also referenced a previously published Fact Sheet (covered by InfoBytes here), which highlights the most pertinent exemptions, exceptions, and authorizations for humanitarian assistance and trade under the Iran, Venezuela, North Korea, Syria, Cuba, and Ukraine/Russia-related sanctions programs to ensure humanitarian-related trade and assistance reaches at-risk populations through legitimate and transparent channels during the global Covid-19 pandemic.
OFAC updates FAQs related to Iranian humanitarian goods manufacturing
On June 5, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued updated Iran-related FAQs related to Executive Order (E.O.) 13902 concerning the treatment of Iranian manufacturers that provide humanitarian goods. As previously covered by InfoBytes, E.O, 13902 authorizes the Secretary of the Treasury, in conjunction with the Secretary of State, to impose asset blocking sanctions on any person determined to operate in the construction, mining, manufacturing or textile sectors of the Iranian economy, or any additional sector as they may jointly determine. Additionally, EO 13902 authorizes the imposition of certain sanctions on any person determined to have engaged in, or any foreign financial institution determined to have knowingly facilitated, a significant transaction involving one of the aforementioned sectors of the Iranian economy. The FAQs state that OFAC will not target persons in Iran manufacturing humanitarian goods, such as “medicines, medical devices, or products used for sanitation or hygiene” as long as the products are “solely for use in Iran and not for export from Iran.” The FAQs also define Iranian economy sectors, specify what constitutes as “significant goods or services,” and clarify the interpretation of “‘knowingly’ and ‘significantly reduced’” for purposes of E.O. 13902. Additionally, on June 8, OFAC added several Iran-related designations to its Specially Designated Nationals List.
OFAC publishes Syria-related sanctions regulations
On June 4, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced the issuance of regulations to implement Executive Order (E.O.) 13894: “Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Syria.” E.O. 13894 was issued last October following the determination that the situation in and in relation to Syria “undermines the campaign to defeat [ISIS].” The final rule implementing the regulations, which was published in an abbreviated form to provide immediate guidance to the public, took effect June 5. OFAC states it “intends to supplement these regulations with a more comprehensive set of regulations, which may include additional interpretive and definitional guidance, general licenses, and statements of licensing policy.”
OFAC sanctions oil companies for supporting Maduro regime, blocks four vessels
On June 2, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) sanctioned four companies for operating in the oil sector of the Venezuelan economy (which provides “financial resources to the illegitimate regime of President Maduro”) and identified four vessels as blocked property, pursuant to Executive Order 13850. As a result, all property and interests in property belonging to the identified entities subject to U.S. jurisdiction are blocked, and “any entities that are owned, directly or indirectly, 50 percent or more by the designated entities are also blocked.” U.S. persons are generally prohibited from dealing with any property or interests in property of blocked or designated persons.
OFAC issues Iran nuclear FAQ
On May 27, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC), in response to the Department of State’s announcement of an end to certain Iran nuclear-related waivers, issued a new FAQ and added two individuals to the Specially Designated Nationals and Blocked Persons List (SDN List). FAQ 829 provides a 60-day wind-down period for persons currently engaged in activities permitted by these waivers; however, OFAC cautions that such activities should be wound down by July 27 or persons risk exposure to sanctions under U.S. law absent another waiver or exception. The FAQ notes that the Iran Freedom and Counter-Proliferation Act “provides for sanctions on persons determined to knowingly provide significant financial, material, technological, or other support to, or goods or services in support of any activity or transaction on behalf of or for the benefit of, an Iranian person on OFAC’s SDN List.”
OFAC designates Iran’s interior minister and senior law enforcement officials for human rights abuses
On May 20, the U.S. Treasury Department's Office of Foreign Assets Control (OFAC), pursuant to Executive Order 13553, sanctioned Iran’s interior minister, in addition to seven senior officials of Iran’s Law Enforcement Forces (LEF), a provincial commander of Iran’s Islamic Revolutionary Guard Corps, and a foundation along with its director and members of the board of trustees, for serious human rights abuses against Iranians. According to OFAC, the foundation is controlled by LEF and plays an active role in Iran’s energy, construction, services, technology, and banking industries. As a result of the sanctions, “all property and interests in property of these persons that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC.” OFAC further noted that its regulations “generally prohibit all dealings by U.S. persons or within (or transiting) the United States that involve any property or interests in property of blocked or designated persons,” and warned foreign financial institutions that knowingly facilitating significant transactions or providing significant financial services to the designated individuals may subject them to U.S. correspondent account or payable-through sanctions.