The Office of Foreign Assets Control on April 1 fined S&P Global, a business analytics firm, $78,750 for violating U.S. Ukraine-related sanctions regulations. OFAC said the case was non-egreious, partly due to S&P's cooperation and agreement to improve its compliance program.
The U.S. and Canada issued more sanctions last week against people and entities in Myanmar responsible for supplying defense equipment to the country’s military regime. The Office of Foreign Assets Control targeted five people and five entities, including several arms dealers and their companies, for supporting the regime. Canada sanctioned four suppliers and two entities, including Myanmar Chemical & Machinery and Yatanarpon Aviation Support. The U.K. announced similar sanctions (see 2203280009).
The Office of Foreign Assets Control has sanctioned Iranian procurement agent Mohammad Ali Hosseini and four Iranian entities that procured ballistic missile propellant-related materials. “This action reinforces the United States’ commitment to preventing the Iranian regime’s development and use of advanced ballistic missiles,” Brian Nelson, undersecretary for terrorism and financial intelligence, said in a news release March 30. “While the U.S. continues to seek Iran’s return to full compliance with the Joint Comprehensive Plan of Action, we will not hesitate to target those who support Iran’s ballistic missile program. We will also work with other partners in the region to hold Iran accountable for its actions, including gross violations of the sovereignty of its neighbors.”
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The U.S. Court of Appeals for the D.C. Circuit upheld the sanctions listing of Russian billionaire Oleg Deripaska, finding that the Treasury Department's Office of Foreign Assets Control provided proper evidence for the listing. The court also held that while Deripaska was found to no longer own two major energy companies, OFAC found him to still operate them, justifying his placement in the Russian sanctions regime.
The past several weeks at U.S. sanctions agencies have ranked among the busiest times in recent memory, especially at the Office of Foreign Assets Control, where some employees are working nearly nonstop to implement and enforce new sanctions against Russia, former officials said in interviews. While some former officials said the extra work could shift minor projects to the side, lawyers are concerned it could also delay more pressing agency priorities, including licensing requests.
The Office of Foreign Assets Control designated six individuals in the United Arab Emirates for raising money on behalf of Boko Haram insurgents in Nigeria. OFAC actions follow arrests in the UAE in September, which OFAC says "demonstrates the commitment of the Emirati government to using judicial measures and targeted financial sanctions to disrupt the flow of funds to these networks."
The Office of Foreign Asset Control on March 24 updated two existing Russia-related general licenses and issued two new licenses. Updated License 6A authorizes certain transactions involving exports of agricultural commodities, medicine, medical devices and COVID-19 diagnosis and treatment equipment, while updated License 17A authorizes certain imports of Russian alcoholic beverages, non-industrial diamonds or seafood. New License 20 authorizes certain transactions involving the official business of third-country diplomatic or consular missions in Russia, and new License 25 authorizes certain transactions involving "journalistic activities" in Russia. OFAC also updated two existing Frequently Asked Questions to reflect the new licenses.
Although the EU has been reluctant to impose an embargo on Russian oil and gas (see 2203230037), the bloc could soon take steps to impose some energy-related trade restrictions, Vladimir Milov, a Russian economist and opposition politician, said during a March 24 event hosted by Chatham House. He said the EU will eventually introduce some “gradual embargo measures,” potentially against refined products or liquefied natural gas. “In terms of European unity, my understanding is they're moving,” he said. “There will be movement in that direction.”
The Biden administration is emphasizing enforcement of Russia sanctions and export controls, making industry compliance with trade restrictions increasingly important, law firms said. Businesses should be taking several due diligence steps to avoid being caught in Russia-related sanctions evasion attempts, they said, and also can take action to protect their business operations in the Russia and Ukraine regions.