OFAC

The Office of Foreign Assets Control sanctioned people and entities in Uganda, Iran and Syria for human rights abuses or for undermining democratic institutions. The designations target military or government officials in all three countries as well as two Iranian law enforcement agencies and two Iranian prisons, OFAC said Dec. 7. The U.S. purposefully issued the sanctions just ahead of its democracy summit later this week, which will convene more than 100 of the world’s democracies to discuss collaboration on human rights issues, anti-corruption and more. “Consistent with the goals of this week’s Summit for Democracy, the United States is committed to using its full range of tools to counter serious human rights abuse and repressive acts across the world,” Secretary of State Antony Blinken said.

The Office of Foreign Assets Control this week sanctioned an additional 20 people, 12 entities and three aircraft for aiding the Alexander Lukashenko regime in Belarus. The agency also imposed new restrictions on dealings in Belarusian sovereign debt, and issued a new general license and 10 new frequently asked questions to provide guidance on the new sanctions.

The Office of Foreign Assets Control last week sanctioned six Iranians and one Iranian entity for trying to influence the 2020 U.S. presidential election. OFAC said they “sought to sow discord and undermine voters’ faith in the U.S. electoral process” through misinformation on social media, “threatening emails” and a video implying that “individuals could cast fraudulent ballots.” The designations targeted the Iranian cyber company Emennet Pasargad, its manager Mohammad Bagher Shirinkar and others affiliated with the company: Seyyed Mohammad Hosein Musa Kazemi, Sajjad Kashian, Mostafa Sarmadi, Seyyed Mehdi Hashemi Toghroljerdi and Hosein Akbari Nodeh. OFAC said it previously designated Shirinkar for supporting the Iranian military and previously sanctioned Emennet Pasargad under its former name: Net Peygard Samavat Co.

The U.S. and more than 30 other countries are meeting virtually this week to discuss how to better counter and disrupt ransomware attacks, including through sanctions, the White House said Oct. 13. The meetings come less than a month after the U.S. sanctioned SUEX, a large virtual currency exchange, for helping to facilitate transactions related to illegal ransomware attacks (see 2109210031). The White House said the Treasury Department “will continue to disrupt and hold accountable these ransomware actors and their money laundering networks,” and the meetings this week could be a forum for discussing multilateral actions.

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.

A Romanian bank and its U.S. parent company were fined about $860,000 by the Office of Foreign Assets Control for violating U.S. sanctions against Iran and Syria, OFAC said in an enforcement notice. Romania-based First Bank SA processed nearly 100 transactions worth about $3.5 million through U.S. banks on behalf of sanctioned parties, the notice said. The bank continued to process transactions for Iranian customers after it was acquired by U.S.-based JC Flowers in 2018.

The Treasury Department’s Financial Crimes Enforcement Network fined one of the world’s largest cryptocurrency exchange companies $100 million for failing to maintain a compliant anti-money laundering program, which violated the Bank Secrecy Act, according to a recent penalty notice. The violations also exposed other BitMEX compliance issues, including its deficient sanctions screening.

President Joe Biden issued a new executive order to expand existing U.S. sanctions authorities against Belarus and issued a host of new designations targeting the country’s government for last year’s “fraudulent” presidential elections. The Aug. 9 order authorizes sanctions against a broad range of government officials, oligarchs, entities and private companies, including those operating in Belarus’ defense, energy, security, potassium chloride, transportation and construction sectors. Sanctions are also authorized against people or entities with links to “public corruption” in Belarus or transactions deemed to be “deceptive or structured” to evade U.S. sanctions on behalf of the Belarusian government.

The Office of Foreign Assets Control fined a New York online money transmitter and provider more than $1.4 million for violating U.S. sanctions on the Crimea region of Ukraine, Iran, Sudan and Syria. Payoneer came to a settlement agreement with OFAC after illegally processing more than 2,000 payments for parties in sanctioned countries, OFAC said in a July notice. The fine was OFAC’s third highest this year.

The Office of Foreign Assets Control sanctioned a senior Cuban official and a government agency for their involvement in the repression of pro-democratic protests on the island this month, OFAC said July 22. The designations target Alvaro Lopez Miera, the Cuban defense minister, and the Brigada Especial Nacional del Ministerio del Interior (also known as the Boinas Negras or the Black Berets). “This is just the beginning,” President Joe Biden said in a July 22 statement. “The United States will continue to sanction individuals responsible for oppression of the Cuban people.”