You can now listen to the audio version of our weekly sanctions updates here.
Monday, March 17
The Council of European Union imposed asset freezing sanctions against Al-Azaim Media Foundation, the media organization of the Islamic State's Khorasan Province. (Decision, and press release)
The Council also imposed asset freezing sanctions against nine individuals and one entity under its sanctions regime against the Democratic Republic of the Congo. (Decision, and press release)
Tuesday, March 18
OFAC imposed blocking sanctions against one individual in Mexico for alleged role in the smuggling of thousands of individuals from Guatemala, through Mexico, and into the United States, under the U.S. sanctions program against Transnational Criminal Organizations. (Here, and the Department of the Treasury's press release)
OFAC published an alert about the recent designations of international cartels discussing sanctions and criminal liability risks for U.S. foreign FIs, and others. (Here)
The U.S. Department of Justice filed a civil forfeiture complaint in the Southern District of Florida against a Dassault Falcon 900 EX aircraft, which was smuggled from the United States under false pretenses and operated for the benefit of Nicolás Maduro in violation of U.S. sanctions and export control laws. The aircraft was seized last year in the Dominican Republic at the request of the United States. The press release and the complaint provide a detailed description of how Venezuelan parties evaded the U.S. sanctions and export controls. (Here)
Wednesday, March 19
There was no major development on this day.
Thursday, March 20
OFSI published a detailed penalty notice in amount of £465,000 against Herbert Smith Freehils Moscow. The violations, which were voluntarily disclosed to OFSI, relate to six payments with the aggregate value of £3,932,392.10 to designated persons. There are several takeaways from this enforcement action namely the value of voluntary disclosures to OFSI, cooperation with OFSI, and the risks associated winding down activities following sanctions. This actions also indicates the importance of the place of incorporation and the application of sanctions of such place on foreign operations. (Here, and press release)
OFAC and State Department imposed blocking sanctions against one individual, 13 entities, and 8 vessels for helping Iran selling its crude oil. The most notable sanctioned entity was Shandong Shouguang Luqing Petrochemical Co Ltd, which was depicted as the first "teapot refinery" designated for purchasing Iranian crude. However, on May 25, 2022, the last administration designated entities including Shandong Sea Right Petrochemical Co. Ltd., which seems to be a "teapot refinery," as well. (Here, the Department of the Treasury's press release, the Department of State's Fact Sheet, and the Department of State's press release) It is interesting that the Treasury's press release, in relevant part, reads that "[i]n mid-2022, Luqing Petrochemical was identified as a buyer of Iranian oil associated with the Iranian military and Iranian military forces[,]" underscoring that this administration will not be shy off designating anyone who engages with Iranian crude.
The EU Commission published 14 new FAQs about the infrastructure transaction ban under Article 5ae of Council Regulation (EU) No 833/2014 (EU's Russia sanctions). (Here)
Friday, March 21
OFSI published its annual review called "OFSI Annual Review 2023-24: Engage, Enhance, Enforce." The publication provides so much information about what OFSI did over the past financial year, which runs from 1 April to 31 March, including figures on designations, licenses, and ongoing and closed enforcement cases. (Here)
OFAC delisted Tornado Cash. The Treasury Department stated that it delisted Tornado Cash based on its discretion and "based on the Administration’s review of the novel legal and policy issues raised by use of financial sanctions against financial and commercial activity occurring within evolving technology and legal environments," however, a federal appellate court had ordered Tornado Cash's delisting back in November. (Here, and the Department of the Treasury's press release)
Recommendation of the Week
Check out the recording of a fantastic event hosted by the Atlantic Council's Economic Statecraft Initiative: The age of economic warfare: Behind US sanctions against Russia, China, and Iran - Atlantic Council
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