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.
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.”
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.
The Treasury’s Office of Foreign Assets Control extended the expiration dates for two Ukraine-related general licenses that authorize certain transactions with U.S.-sanctioned GAZ Group, OFAC said in a March 20 notice. General License No. 13N authorizes certain transactions necessary to divestments and debt transfers. General License No. 15H authorizes certain transactions related to the maintenance or wind down of operations of existing contracts, and activities related to certain automotive safety and environmental systems in vehicles produced by GAZ Group.
The Treasury’s Office of Foreign Assets Control sanctioned five United Arab Emirates companies for buying Iranian oil, Treasury said in a March 19 press release. The companies bought “hundreds of thousands” of metric tons of petroleum products from the National Iranian Oil Company, which was sanctioned by OFAC in 2008. The companies include Petro Grand FZE, Alphabet International DMCC, Swissol Trade DMCC, Alam Althrwa General Trading LLC and Alwaneo LLC Co.
The Treasury’s Office of Foreign Assets Control added one entry to its Specially Designated Nationals List, removed 13 others and amended two additional entries, according to a March 17 notice. OFAC also deleted four entries from its Foreign Sanctions Evaders List. The agency added Ali Abdullah Ayoub, Syria’s defense minister, to its SDN List, while deleting several entries for entities based in the Democratic Republic of the Congo, Cyprus, Switzerland and Syria. Treasury did not immediately release more information on the sanctions.
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The Treasury’s Office of Foreign Assets Control issued a Venezuela-related designation, amended three Venezuela-related general licenses and amended two frequently asked questions, according to a March 12 notice. The designation targets Switzerland-based TNK Trading International S.A. for operating in Venezuela’s oil sector. The company is a subsidiary of Russian state-controlled Rosneft Oil Company, according to a press release.
The Treasury’s Office of Foreign Assets Control sanctioned four Mexican businesses because of their links to Cartel de Jalisco Nueva Generacion (CJNG) and the Los Cuinis Drug Trafficking Organization, Treasury said in a March 11 news release. The designated companies include the asset holding company International Investments Holding S.A. de C.V. and a gas station company GBJ de Colima, S.A. de C.V. The two companies have been involved in helping Los Cuinis and CJNG to evade U.S. sanctions.