The Treasury’s Office of Foreign Assets Control added three Russian nationals and one Russian entity to its Specially Designated Nationals List, OFAC said in an April 6 notice. The sanctions target Denis Valiullovich Gariyev, Nikolay Nikolayevich Trushchalov, Stanislav Anatolyevich Vorobyev and the Russian Imperial Movement. OFAC did not immediately release more information on the designations.
The Federal Aviation Administration does not independently vet civil aircraft registrations, which could lead to a host of sanctions related risks, according to a March report from the Government Accountability Office. In at least one case, the FAA allowed a sanctioned Venezuelan drug trafficker to obtain a dealer certificate, which gave his front company access to blocked planes for more than a year, the GAO said. FAA officials said they do not have the required authorities to address sanctions issues, but the GAO pointed to a lack of coordination between FAA and the Treasury's Office of Foreign Assets Control and a flawed FAA registration system.
The Treasury’s Office of Foreign Assets Control extended the expiration date for a Venezuela-related general license, OFAC said in an April 3 notice. General License No. 13E, which replaces No. 13D (see 1910170057), authorizes certain transactions involving Nynas AB, a joint venture between biofuel producer Neste and Petroleos de Venezuela, Venezuela's state-run oil company. OFAC extended the expiration because Nynas is discussing with OFAC a “proposed corporate restructuring” that could “result in significant changes to Nynas AB’s ownership and control,” the notice said, and the expiration will “afford additional time to complete this engagement.” The license, which was scheduled to expire April 14, will now expire May 14.
Companies involved in sanctions compliance should closely communicate with regulators during the COVID-19 pandemic and carefully document compliance procedures during work-from-home operations, according to Nicole Sayegh Succar, a trade lawyer with Crowell & Moring. Those steps could minimize scrutiny and potential sanctions penalties after the pandemic subsides, Succar said during an April 2 webinar hosted by the law firm.
The Trump administration should issue “broad licenses” to medical companies and create dedicated channels for industry to export medical goods to Iran during the COVID-19 pandemic, former Vice President Joe Biden said April 2. Although the Treasury's Office of Foreign Assets Control already has broad general licenses that allow exemptions for humanitarian exports, Biden said they are not effective. “In practice, most governments and organizations are too concerned about running afoul of U.S. sanctions to offer assistance,” Biden said. “As a result, our sanctions are limiting Iran’s access to medical supplies and needed equipment.”
Expectations for sanctions compliance are increasing amid the COVID-19 pandemic as both U.S. and United Kingdom agencies continue sanctions enforcement, trade lawyers said. The U.S. Treasury Department Office of Foreign Assets Control and the U.K. Office of Financial Sanctions Implementation continue to issue sanctions, pursue enforcement and expect heightened due diligence from industry, the lawyers said, “You've got OFAC doing its continuing expansion of U.S. sanctions and … you've got increasing pressure from even the U.K.,” said David Wolff, a trade lawyer with Crowell & Moring, speaking during an April 2 webinar hosted by the law firm. “The regulatory expectations, if anything, are getting worse.”
Rosneft, the U.S.-sanctioned Russian energy company, has stopped operating in Venezuela and sold “all of its interest” in Venezuelan businesses, the company said March 28. Rosneft said it will no longer participate in “joint ventures” with Venezuelan entities “as well as oil-field services companies, commercial and trading operations.” The company’s announcement came weeks after the Treasury’s Office of Foreign Assets Control sanctioned Rosneft subsidiaries for operating in Venezuela (see 2002180033 and 2003120033). Rosneft has criticized U.S. sanctions, calling them illegal and saying in February it was seeking “legal protection” (see 2002210022).
The Treasury’s Office of Foreign Assets Control sanctioned 20 Iranian and Iraqi front companies, officials and business associates that support the Islamic Revolutionary Guards Corps-Qods Force, Treasury said in a March 26 press release. The sanctioned parties also participated in smuggling, money laundering and illegal oil sales. Among the sanctioned parties are Iraq-based Al Khamael Maritime Services, Iran- and Iraq-based Mada’in Novin Traders and Iran-based Middle East Saman Chemical Company.
The Treasury’s Office of Foreign Assets Control made “minor technical amendments” to two Nicaragua-related general licenses, according to a March 25 notice. OFAC issued amended General License No. 1A, which authorizes certain transactions with Nicaragua by the U.S. government, and General License No. 2A, which authorizes the wind down of certain transactions involving the Nicaraguan National Police.
Companies will likely be faced with a reshuffled supply chain after the novel coronavirus COVID-19 pandemic subsides, placing greater importance on maintaining sound trade compliance programs even as business uncertainty increases, said Kerry Contini, an export control and sanctions lawyer with Baker McKenzie. As supply chain actors struggle to stay in business and as new parties enter and leave the supply chain, companies may face a host of new suppliers or customers, Contini said, a transition that will likely affect global industries on a large scale.