The Office of Foreign Assets Control this week updated one entry on its Specially Designated Nationals List that is listed for being a Russia-related secondary sanctions risk. The change updates identifying information for Meroe Gold Co. LTD, which was sanctioned in 2020 for being a subsidiary of M Invest, a Russian company owned by now deceased Russian oligarch Yevgeniy Prigozhin.
The Bureau of Industry and Security added 42 parties to the Entity List for helping to illegally supply parts and drones to Russia’s military industrial base, performing contracts for Russian government entities or for doing business with sanctioned companies. The companies and people added to the list are located in China, Cyprus, Germany, Kazakhstan, the Netherlands, Russia and the United Arab Emirates.
The U.K. amended one entry under its Russia sanctions regime and five entries under its Libya sanctions regime in a pair of Nov. 30 notices from the Office of Financial Sanctions Implementation. The listing for Mihajlo Perencevic under the Russia restrictions was altered to reflect that he is the former, not current, president of construction, energy and extractive firm Velesstroy. Under the Libya restrictions list, OFSI amended the entries for Osama Al Kuni Ibrahim, Abd Al-Rahman Salim Ibrahim Al-Milad, Mohammed Al Amin Al-Arabi Kashlaf, Saadi Qadhafi and Sayyid Mohammed Qadhafi.
The EU General Court on Nov. 29 accepted the second application from Alexander Pumpyanskiy, son of Russian oligarch Dmitry Pumpyanskiy, to annul his sanctions relisting, according to an unofficial translation. The court rejected his claim for damages. Pumpyanskiy was sanctioned in March 2022 after Russia's invasion of Ukraine, because of his relationship to Dmitry Pumpyanskiy, and because he was president and board member of the Sinara Group.
The Office of Foreign Assets Control sanctioned a Guatemalan ex-official last week for engaging in widespread bribery schemes, including schemes related to government contracts, OFAC said in a news release. Luis Miguel Martinez Morales is former head of the now-defunct Centro de Gobierno, and used that position to influence the “government contracts process to benefit himself and close associates,” OFAC said. He also “solicited large kickbacks to facilitate the purchase of the Russian Sputnik V vaccines by the Government of Guatemala,” OFAC said. Martinez was designated under the Global Magnitsky Human Rights Accountability Act, the agency said.
The Office of Foreign Assets Control last week sanctioned three companies and three vessels for violating the Group of 7 price cap on Russian crude oil. The agency also issued a new general license authorizing certain safety and environmental-related transactions involving those vessels.
End-use certificates can be a good way to mitigate some sanctions and export control risk, but “it doesn't necessarily make the risk completely disappear,” said Jan Dunin-Wasowicz, a Hughes Hubbard trade lawyer. Dunin-Wasowicz cautioned companies about relying solely on end-use and end-user statements when conducting due diligence, adding that companies can take other compliance steps to vet a transaction, especially because some customers are willing to lie about a product's end-use.
The EU General Court on Nov. 29 rejected Russian oligarch German Khan's challenge to his sanctions listing, according to an unofficial translation. The listing criteria had a proper legal basis and were not disproportional, the court said.
The Office of Foreign Assets Control this week sanctioned eight North Korean agents for their work facilitating sanctions evasion – six of them based in third countries – in an action the agency said comes in response to a recent military reconnaissance satellite launch by North Korea. The North Korean agents, including Russia-based Un Hyok Choe and Myong So, China-based Myong Chol Jang and Phyong Guk Kang, and Iran-based Kyong Il Kang and Sung Il Ri, engage in revenue generation and missile-related technology procurement in support of North Korea’s weapons of mass destruction program, OFAC said.
A new bipartisan bill in the Senate and House would allow DOJ to “more quickly” seize sanctioned Russian assets through existing forfeiture processes and transfer proceeds from those assets to help Ukraine’s reconstruction efforts. The Asset Seizure for Ukraine Reconstruction Act, introduced this week, would lift the $500,000 cap on administrative forfeitures of assets owned by Russian oligarchs and others, and would also “clarify DOJ’s transfer authority, ensuring that the U.S. government can transfer to Ukraine all the funds it acquires through seizure of Russian oligarch assets,” according to a news release.