The Office of Foreign Assets Control’s August penalty against a Romanian bank and its U.S. parent company underscored the various sanctions risks during acquisitions and the many compliance issues foreign subsidiaries can cause for their owners, law firms said. The settlement agreement particularly served as a reminder to non-U.S. companies that OFAC’s sanctions jurisdiction can extend far beyond the U.S., and there are “no shorthand compliance measures that can guarantee protection,” Arnold & Porter said in a September alert.
The Office of Foreign Assets Control on Sept. 17 sanctioned a network of Lebanon- and Kuwait-based financial conduits as well as a network of financial facilities that support Hezbollah and Iran’s Islamic Revolutionary Guard Corps-Qods Force. The networks have helped launder tens of millions of dollars on behalf of terrorist groups and conduct currency exchange operations and trades in gold and electronics” for both Hezbollah and IRGC-QF, OFAC said.
The Office of Foreign Assets Control on Sept. 17 issued another reminder (see 2107070005) to industry to file annual reports on blocked property by Sept. 30. The reports should disclose blocked property held as of June 30. The OFAC notice includes a link to the blocked property report spreadsheet and guidance on filing the reports.
President Joe Biden issued an executive order last week authorizing a range of sanctions and export restrictions against human rights abusers and other people committing violence, blocking humanitarian aid or threatening peace in Ethiopia. The new sanctions regime can target the Ethiopian and Eritrean government and several military groups in the region, including the Ethiopian National Defense Forces, the Eritrean Defense Forces, the Tigray People’s Liberation Front and Amhara regional forces, and others supporting those groups and people. In addition to asset freezes, the order authorizes the Treasury Department to work with other agencies to deny export licenses for certain goods and technology to people or entities sanctioned under this regime.
The Office of Foreign Assets Control on Sept. 16 sanctioned two entities and four people for operating as a “significant” drug trafficking organization. The designations target Zulma Maria Musso Torres, Washington Antunez Musso, Juan Carlos Reales Britto and Luis Antonio Bermudez Mejia for their involvement in drug trafficking. Antunez Musso, Reales Britto, and Bermudez Mejia report to Musso Torres, OFAC said, and help her traffic drugs at Colombian seaports. The four persons include husband and wife and the wife's two sons. OFAC also designated two Colombian entities, Exclusive Import Export S.A.S. and Poligono Santa Marta S.A.S., which are controlled by Antunez Musso and Reales Britto.
The Office of Foreign Assets Control on Sept. 16 sanctioned five al-Qaida supporters in Turkey who provide a “range of financial and travel facilitation services” to the terrorist group. The designations target Majdi Salim, Muhammad Nasr al-Din al-Ghazlani, Nurettin Muslihan, Cebrail Guzel and Soner Gurleyen.
The Biden administration is likely to increase export controls and sanctions enforcement in the next few years, Gibson Dunn lawyers said during a webinar this week. They also said the administration is likely to pursue enforcement in creative ways, including sometimes through disclosures with the Committee on Foreign Investment in the U.S.
Three members of a Florida family were charged with conspiracy to violate U.S. sanctions on Iran and money laundering, the Department of Justice said. Mohammad Faghihi, along with his wife, Farzeneh Modarresi, and sister, Faezeh Faghihi, led Florida-based Express Gene -- a company that allegedly received multiple wire transfers from accounts in Malaysia, China, Singapore, Turkey and the United Arab Emirates, totaling nearly $3.5 million, between October 2016 and November 2020. Some of this money allegedly was used to buy and then ship genetic sequencing equipment to Iran without a license from the Treasury Department's Office of Foreign Assets Control, DOJ said.
Export Compliance Daily is providing readers with the top stories for Sept. 7-10 in case you missed them. You can find any article by searching the title or by clicking on the hyperlinked reference number.
The Office of Foreign Assets Control on Sept. 13 amended two Russia-related entries on its Specially Designated Nationals List. The entries are for Russia’s 27th Scientific Center and the 33rd Scientific Research and Testing Institute, both of which were sanctioned in March in response to the Russian government’s poisoning and imprisonment of opposition leader Alexei Navalny (see 2103020067).