Monday, January 8
A California resident and Russian national pleaded guilty to attempting to provide material support to Hayat Tahrir al-Sham, a designated foreign terrorist organization. (Here)
Tuesday, January 9
FinCEN issued a Financial Trend Analysis on information linked to identity-related suspicious activity in Bank Secrecy Act (BSA) reports filed in 2021. (Here, Financial Trend Analysis)
France imposed asset-freezing sanctions on one individual under France’s autonomous counter-terrorism sanctions program. (Here)
Wednesday, January 10
The Export Control Joint Unit (ECJU) released a notice to exporters on best practices for license applications. (Here)
Thursday, January 11
OFAC imposed asset-freezing sanctions on one individual, two entities, and three aircraft. (Here)
Potential sanctions violations penalties just got more expensive! OFAC amended its regulations to implement the Federal Civil Penalties Inflation Adjustment Act. This amendment adjusts for inflation, the maximum amount of civil monetary penalties that may be assessed under relevant OFAC regulations (Here, Inflation Adjustment of Civil Monetary Penalties Amendment)
The Department of State imposed asset-freezing sanctions against three Russian entities and one individual, and identified four aircraft as blocked property, for their involvement in the transfer and testing of Democratic People’s Republic of Korea ballistic missiles for Russia’s use against Ukraine. (Here, Fact-Sheet)
France imposed asset-freezing sanctions on two entities under France’s autonomous counter-terrorism sanctions regime. (Here)
Friday, January 12
OFAC imposed asset-freezing sanctions on two companies and identified four vessels as blocked property for their involvement in shipping Iranian commodities on behalf of IRGC-QF-backed Houthi financial facilitator, Sa’id al-Jamal. OFAC removed asset-freezing sanctions on one aircraft. (Here, Department of Treasury press release, Department of State press release)
FinCEN has updated its Beneficial Ownership Information Frequently Asked Questions. (Here)
The Bureau of Industry and Security (BIS), under the Department of Commerce, is seeking OMB approval for an information collection extension regarding import, end-user, delivery verification certificates, and firearms entry clearance requirements. (Here)
The EU Council established a dedicated framework for restrictive measures in support of democracy and a peaceful and orderly transfer of power in Guatemala, and to hold accountable those obstructing a democratic transition following the 2023 general elections. Any targeted restrictive measures shall consist of a travel restriction for individuals and an asset freeze for individuals and entities. Please note that no one is sanctioned under this program yet. (Decision, EU Council Press release)
Recommendations of the Week
Sanctions Expert partner, International Sanctions and Export Control Society, is working on a feedback survey which will be shared with the relevant authorities in the U.S. Government. This is a great opportunity to share your concerns with U.S. officials concerning export controls and sanctions. Here is the link to the survey: Gov Feedback Survey (The deadline to share your comments is January 31, 2024.)
K2 Integrity sanctions team published an alert about the recent expansion of the U.S. sanctions program. It has listed some practical points for Foreign Financial Institutions on managing the recently-emerged risk of "secondary" sanctions. Check it out here: Sanctions Against Russia: U.S. Introduces New Russia-Related Sanctions Targeting Foreign Financial Institutions And Tightens Other Restrictions
Wolfsburg Group updated guidance for Swift Relationship Management Application (RMA) due diligence. You can find the updated version here: Swift RMA Guidance
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