Monday, January 13
OFAC and OFSI published a Memorandum of Understanding (MoU) between them. The MoU establishes a framework for collaboration in enforcing and promoting compliance with economic and trade sanctions. The MoU aims to strengthen the partnership between OFAC and OFSI by facilitating: information sharing relevant to sanctions enforcement; coordinated investigations; personnel training; discussions on regulatory expectations; economic analysis; and development of practical arrangements to enhance sanctions administration. (Here)
OFSI issued General License INT/2025/5632740 under the UK Autonomous Sanctions Regulations listed in Annex 1 of the General License (there are 25 programs listed in that annex), which allows UK persons to make funds available to or for the benefit of a designated person up to GBP 350 in each of the two months following the date of the designation for the purpose of food and beverages, medicines/medical products, and personal and household products. (Here)
The EU Council extended the sanctions regime against those who support, facilitate, or enable violent actions by Hamas and the Palestinian Islamic Jihad for another year.(Here, and press release)
The Department of State is designating the Terrorgram Collective (Terrorgram) and three of its leaders as Specially Designated Global Terrorists pursuant to Executive Order (E.O.) 13224, as amended. (Here, the Department of State's Fact Sheet, and the Department of State's press release)
Tuesday, January 14
There were no major developments on this day.
Wednesday, January 15
In a flurry of actions before the change in the administration, BIS:
Added 16 entities to the Entity List, including AI companies that are furthering the PRC’s goals of indigenous advanced chip production. BIS also updated some rules related to the export of advanced computing semiconductors; (Here)
In a separate rule, added 11 entities to its Entity List because these entities are advancing the PRC's military modernization through the development and integration of advanced artificial intelligence research; (Here)
Published a fact sheet that described the actions BIS took over the past four years. (Here); and
Released an Interim Final Rule implementing targeted export controls on certain laboratory instruments. (Here)
In its last Russia-related sanctions move, the Biden administration imposed blocking sanctions against 250 "enablers." This batch of designations included several regional clearing platforms, a bank in Kyrgyzstan, several companies active in the Russian energy sector, and others. Several designations were made under the authorities given in Executive Orders (E.O.) 14024 and 13662. Additionally, almost 100 entities already designated pursuant to E.O. 14024 were also designated under E.O. 13662. This is important since the sanctions imposed pursuant to E.O. 13662 are mandated by the Congress and may not be removed without Congress's approval. Simultaneously, OFAC issued Russia-related General License 122, "Authorizing the Wind Down of Transactions Involving Certain Entities Blocked on January 15, 2025;" Russia-related General License 123, "Authorizing Certain Transactions Related to Debt or Equity of, or Derivative Contracts Involving, Wafangdian Bearing Company Limited;" and Russia-/Ukraine-related General License 26A, "Transactions Authorized Pursuant to the Russian Harmful Foreign Activities Sanctions Regulations." (Here, the Department of the Treasury's press release, the Department of State's Fact Sheet, and the Department of State's press release)
OFAC amended its regulations to implement for 2025 the Federal Civil Penalties Inflation Adjustment Act of 1990, as amended. This regulatory amendment adjusts for inflation the maximum amount of the civil monetary penalties that may be assessed under relevant OFAC regulations. (Here)
President Biden issued an E.O. that amended E.O. 13894Â by removing references to the government of Turkey. (Here)
Thursday, January 16
France imposed asset-freezing sanctions against one individual under France's autonomous counter-terrorism sanctions. (Here)
President Biden issued an E.O. that amended E.O. 13694 by enlarging the grounds for designation. (Here)
OFAC announced a $1,076,923 settlement with a Miami, Florida-based natural U.S. person and their real estate company Family International Realty LLC regarding their potential civil liability for apparent violations of OFAC's Ukraine-/Russia-related sanctions. Between 2018 and 2023, Family International Realty and its owner engaged in a willful scheme to evade OFAC sanctions by concealing the property interest of two sanctioned Russian oligarchs in luxury condominiums and profiting from the rental and sale of the properties, thereby committing 73 apparent violations U.S. sanctions against Russia. (Here)
OFAC imposed blocking sanctions against two individuals and one entity under its Sudan sanctions program for being involved in weapons procurement for a sanctioned entity. Â (Here, the Department of the Treasury's press release, and the Department of State's press release)
OFAC imposed blocking sanctions against two individuals and four entities for generating illicit revenue for the Democratic People’s Republic of Korea government. (Here, and the Department of the Treasury's press release)
Friday, January 17
OFAC imposed blocking sanctions against 13 individuals and one entity under its Balkan-related sanctions program. The Republika Srpska President Dodik’s patronage network and individuals in Bosnia and Herzegovina for undermining regional peace and rule of law were among the sanction targets. (Here, the Department of the Treasury's press release, and the Department of State's press release)
OFAC imposed blocking sanctions against eight Venezuelan officials who lead key economic and security agencies in Venezuela. (Here, the Department of the Treasury's press release, and the Department of State's press release)
OFAC imposed blocking sanctions against a Shanghai-based cyber actor who was involved with the recent Department of the Treasury network compromise under the U.S. cyber sanctions program. Additionally, OFAC imposed blocking sanctions against a China-based company that recently compromised the network infrastructure of multiple major U.S. telecommunication and internet service provider companies. (Here, the Department of the Treasury's press release, and the Department of State's press release)
OFAC and BIS concurrently imposed civil penalties against Haas Automation, Inc. (Haas) for alleged and apparent violations of U.S. export controls and sanctions laws. Between December 2019 and March 2022, Haas indirectly supplied one computer numerical control (CNC) machine, 13 orders of spare parts, and seven authorization codes for CNC machines owned by blocked Russian entities, thereby committing 21 apparent violations of Executive Orders 13661 and 13662. Those transactions also involved parties that were added to the Entity List for supporting the defense sectors of China or Russia. As part of a settlement agreement with Haas, BIS issued an order imposing an administrative penalty of $1.5 million, as well as an ongoing audit and reporting requirement. Haas also entered a corresponding settlement with OFAC whereby Haas agreed to a $1,044,781 civil penalty to resolve apparent violations of OFAC’s sanctions regulations involving Russia and Ukraine. (OFAC's notice, and BIS's press release)
Recommendation for the week
Don't miss this webinar from OFSI: High Value Dealers & Art Market Participants Webinar, Thursday, Jan 23, 2025 at 1:00 PM GMT (Link to registration)