Monday, February 3
There were no major developments on this day.
Tuesday, February 4
The U.S. President issued a National Security Presidential Memorandum (NSPM-2) which calls for the restoration of "maximum pressure" on Iran. (Here) Among other things, NPSM-2 requires the Secretary of the Treasury to:
immediately impose sanctions or appropriate enforcement remedies on all persons for which the Department has evidence of activity in violation of one or more Iran-related sanctions;
implement a robust and continual sanctions enforcement campaign with respect to Iran that denies the regime and its terror proxies access to revenue;
review for modification or rescission any general license, frequently asked question, or other guidance that provides Iran or any of its terror proxies any degree of economic or financial relief;
issue updated guidance to all relevant business sectors including shipping, insurance, and port operators, about the risks to any person that knowingly violates United States sanctions with respect to Iran or an Iranian terror proxy; and
maintain countermeasures against Iran at the Financial Action Task Force, evaluate beneficial ownership thresholds to ensure sanctions deny Iran all possible illicit revenue, and evaluate whether financial institutions should adopt a “Know Your Customer’s Customer” standard for Iran-related transactions to further prevent sanctions evasion.
Wednesday, February 5
The U.S. Attorney General issued a department-wide memorandum discussing the shifts in the enforcement priorities of the U.S. Department of Justice. Notably, the Task Force KleptoCapture, the Department's Kleptocracy Team, and the Kleptocracy Asset
Recovery Initiative, will be disbanded. Those resources will be focused to prosecuting Cartels and Transnational Criminal Organizations (TCOs). (Here)
Thursday, February 6
The U.S. President issued an Executive Order re-introducing sanctions against the International Criminal Court (ICC) and designated Karim Khan, Prosecutor of the ICC. (Here)
OFAC imposed blocking sanctions against six individuals, nine entities (located in Iran, India, Hong Kong, the Marshals Islands, and Seychelles, and the UAE) and three vessels for allegedly being involved in a network for facilitating the shipment of millions of barrels of Iranian crude oil worth hundreds of millions of dollars to the People’s Republic of China. (Here, the Department of the Treasury's press release, the Department of State's press release)
FinCEN assessed a $37,000,000 civil money penalty against Brink’s Global Services USA, Inc., an armored car company, for willful violations of the Bank Secrecy Act. As a result of Brink’s failures, hundreds of millions of dollars in bulk currency shipments were transmitted across the Southwest Border on behalf of high-risk entities—including a Mexican currency exchanger that later pleaded guilty to violating the BSA. (Here)
Friday, February 7
The U.S. Justice Department seized an aircraft used by Petroleos de Venezuela, S.A. (PdVSA), the sanctioned Venezuelan state-owned oil and natural-gas company, at the based on violations of U.S. export control and sanctions laws. (Here)
Recommendation for the week
Check out the recording of a webinar titled "Sanctions Policy and Enforcement: What to Expect Under the Trump Administration" by Nicole Erb, a partner at White & Case LLP , and Britt Mosman, a partner Willkie: Webinar | Economic Sanctions Enforcement and Compliance (The webinar is scheduled to be held on Feb. 11, 2025, 11 am ET and the recoding might become available with some delay.)
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