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Last week's major developments in sanctions - January 29th, 2024, to February 2nd, 2024

Monday, January 29

  • FinCEN issued a finding and notice of proposed rulemaking (NPRM) that identifies Al-Huda Bank in Iraq as a foreign financial institution of primary money laundering concern pursuant to Section 311 of the USA PATRIOT Act. Additionally, OFAC imposed asset-freezing sanctions on the bank owner for his involvement with terrorist financing and money laundering. (Here, Department of Treasury press release, FinCEN press release, Department of State press release)

  • OFAC and OFSI imposed asset-freezing sanctions on eleven individuals for their involvement in activities that targeted Iranian dissidents and opposition activists for assassination. (Here, Department of Treasury press release, Department of State press release, OFSI press release)

  • OFAC issued a Venezuela-related general license authorizing the wind down of transactions involving CVG Compania General de Mineria de Venezuela CA (Minerven), or entities owned 50% or more by it. (Here, Department of State press release)

  • The EU Council extended asset-freezing sanctions against Russia for six more months until July 31, 2024, for their continued involvement in destabilizing Ukraine. (Council Decision, press release)

  • The EU Council imposed asset-freezing sanctions against four individuals and one entity under the EU’s Global Human Rights Sanctions Regime. They were sanctioned for their involvement in the continuing deterioration of the human rights situation in Russia. (Council Decision, press release)

  • BIS issued an NPRM for establishing new requirements for Infrastructure as a Service providers. This NPRM can lead to drastic changes in the regulatory landscape for many technology companies. (Press release)

  • The EU Council extended its Tunisia sanctions regime through January 31, 2025, and delisted three entries. (Council Decision)


Tuesday, January 30


Wednesday, January 31

  • A UK citizen was sentenced to 18 months in jail for violations of the International Emergency Economic Powers Act and Iranian Transactions and Sanctions Regulations for involvement in exporting and attempting to export U.S. technology to Iran. (Here)

  • Four Chinese nationals were charged in an indictment in D.C. for their involvement in a years-long operation to export U.S.-origin electronic goods into Iran. (Here)

  • On a busy day on the OFAC, it:  

  • FinCEN imposed a $100,000 civil money penalty on Gyanendra Kumar Asre, the BSA officer of a credit union, for willful violations of the Bank Secrecy Act (BSA) and its implementing regulations. FinCEN’s action also imposes a five-year ban on Asre’s participation in the conduct of the affairs of any financial institution subject to the BSA. (Here)


Thursday, February 1

  • President Biden issued a new executive order "Imposing Certain Sanctions on Persons Undermining Peace, Security, and Stability in the West Bank." (Executive Order)

  • OFAC imposed asset-freezing sanctions on four Israeli settlers for their involvement in violence against Palestinians in the West Bank. (Here, Department of State fact sheet, Department of State press statement)

  • FinCEN issued an alert related to the financing of Israeli extremist settler violence against Palestinians in the West Bank, including red flags to assist institutions in identifying and reporting suspicious activity that finances violence. (Here)

  • OFSI imposed asset-freezing sanctions against four entities under its Myanmar sanctions regime. (Here, press release)

  • OFAC along with OFSI and other G7+ countries published a Price Cap Coalition enforcement alert containing an overview of Oil Price Cap evasion methods and recommendations for identifying and mitigating these risks. (OFAC version, OFSI version)


Friday, February 2 

  • The Justice Department unsealed three federal cases against nine individuals for their involvement in the trafficking and selling of Iranian oil to buyers in China, Russia, and Syria. The Justice Department seized $108 million and 500,000 barrels of oil. (Here)

  • OFAC imposed asset-freezing sanctions against six officials in the Iranian Islamic Revolutionary Guard Corps Cyber-Electronic Command for their involvement in a series of malicious cyber activities against critical infrastructure in the United States and other countries. (Here, the Department of the Treasury’s press release, the Department of State’s press release) 

  • OFAC also imposed asset-freezing sanctions against four Iran- and Hong Kong-based entities for their being part of Iran UAV’s procurement network. (Here, the Department of the Treasury’s press release, the Department of State’s press release) 

  • OFAC amended a Venezuela-related FAQ and published a new Venezuela-related FAQ (Updated FAQ, New FAQ)

  • The EU Council imposed asset-freezing sanctions against five individuals for their involvement in undermining democracy in Guatemala. (Council Decision, press release)

  • The EU Council renewed the sanctions regime against Zimbabwe for one more year until February 20, 2025. (Council Decision, press release)

  • OFSI imposed asset-freezing sanctions against four entities for their involvement in undermining democracy, the rule of law, and good governance in Myanmar. (Here)


Recommendation for the week:

  • The FT published a report on how front companies in the UK facilitated transactions related to Iran’s energy sector using major UK financial institutions.  Check out the story here: Iran used Lloyds and Santander accounts to evade sanctions (ft.com) 

  • Have you ever wondered how North Korea acquires high-end luxury goods despite sanctions?  I came across this old work of C4ADS and NYT about how the country got two armored Mercedes back in 2019. I thought it might be interesting for you too - see the video at the bottom of the page: Lux & Loaded - C4ADS 

  • As we are approaching the second anniversary of Russia’s invasion of Ukraine in 2022, I will start to add links to webinars about it. Check out this week’s pick here: Limiting Russia's Capacity to Wage Wars: Two Years After the Invasion 

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