The Treasury’s Office of Foreign Assets Control issued a “finding of violation” against U.S.-based State Street Bank and Trust Co. (SSBT) after it violated U.S.-imposed sanctions on Iran, OFAC said in a May 28 notice. The bank was not fined, OFAC said, partly because the bank’s managers were likely unaware of the violations and because the bank cooperated with OFAC and improved its compliance program.
The Treasury’s Office of Foreign Assets Control announced sanctions on Argentina-based Goldpharma, which it called a drug trafficking and money laundering organization, and several of its members, Treasury said in a May 23 notice. In total, OFAC designated the company, eight Argentine nationals and 16 other entities under the Foreign Narcotics Kingpin Designation Act for operating as “significant foreign narcotics” traffickers and contributing to the “synthetic opioid crisis,” Treasury said.
The Treasury’s Office of Foreign Assets Control sanctioned five people and one entity under the Sergei Magnitsky Rule of Law Accountability Act for Russia-related human rights violations, Treasury said in a May 16 notice. The sanctioned people include Russian government investigators and members of the Chechen Republic’s Terek Special Rapid Response Team.
The Treasury’s Office of Foreign Assets Control sanctioned 11 people and 10 entities in Mexico related to allegations of corruption, money laundering, drug trafficking and killings, Treasury said in a May 17 notice. The sanctions include the designation of a Mexican magistrate judge and former Mexican governor, Isidro Avelar Gutierrez, under the Foreign Narcotics Kingpin Designation Act.
Speaking at a cryptocurrency conference in New York, Sigal Mandelker, Treasury’s under secretary for terrorism and financial intelligence, said more countries are turning to digital currencies to evade U.S. sanctions. She also stressed the importance of complying with the Office of Foreign Assets Control sanctions programs, rejected the notion of a “one-size-fits-all” compliance program and warned that Treasury is looking into small actors -- not just large companies -- who commit violations.
Export Compliance Daily is providing readers with some of the top stories for May 6-10 in case they were missed.
The Treasury’s Financial Crimes Enforcement Network issued a guidance document and an advisory on regulations and illegal activity in convertible virtual currency fields, FinCEN said in a May 9 press release. The advisory aims to help companies identify and report “suspicious activity” related to the exploitation of CVCs for money laundering and sanctions evasions, FinCEN said, including recognizing “red flags.” In the advisory, FinCEN urges companies to screen their customers and business partners against the Office of Foreign Assets Control’s Specially Designated Nationals List and take “appropriate steps” to stop people in sanctioned countries from “trading in digital currency.” Businesses dealing in virtual currencies should have procedures in place to block IP addresses associated with sanctioned entities, disable accounts of holders from sanctioned countries, “install a dedicated Compliance Officer” to oversee compliance with all OFAC sanctions programs and ensure OFAC compliance training for all pertinent personnel, the advisory said.
The Treasury's Office of Foreign Assets Control sanctioned two companies and two ships for operating in the Venezuelan oil sector, Treasury said in a May 10 press release. As part of the announcement, it said that Treasury Secretary Steven Mnuchin and Secretary of State Mike Pompeo “determined that persons operating in the defense and security sector of the Venezuelan economy” may be sanctioned.
The Treasury’s Office of Foreign Assets Control removed sanctions on a former Venezuelan government official after he “broke ranks” with the Nicolas Maduro regime last week, OFAC said in a May 7 notice. OFAC said Manuel Ricardo Cristopher Figuera, the director general of Venezuela’s National Intelligence Service, was sanctioned in February as a member of the Venezuelan government. All of Cristopher’s property is now unblocked and transactions with him are allowed, the notice said.
The Treasury’s Office of Foreign Assets Control left out several key components of an effective compliance program in its recent sanctions compliance guide, according to a May 6 report from law firm Paul Hastings. The report said the guide should have included descriptions and instructions for “a confidential reporting process,” an "investigations process,” “disciplinary measures for employees which fail to follow the program” and “an emphasis” on mid-level employees stressing the importance of compliance instead of just senior management. The report said these components “appear in guidance documents in other areas” and "it is not clear why OFAC chose to omit these nuances … but no doubt practitioners will seek further clarification from OFAC in the weeks and months to come.” The guide, published May 6, represented an escalating step in OFAC’s effort to disseminate information about effective compliance programs, potentially allowing the agency to more successfully prosecute compliance cases (see 1905030055). The guide provides details of compliance programs that are “now all but mandatory in OFAC’s opinion,” the report said.