Ghost Fleet Update – US probes 30 ship managers for information regarding 100 vessels suspected of Russia oil sanctions violations.

On November 10, 2023, the Office of Foreign Assets Control (“OFAC”) sent notices to ship management companies in nearly 30 countries inquiring about the operations of 100 vessels suspected of facilitating operations in violations of U.S. sanctions related to Russian oil. While OFAC refused to “confirm or comment on investigations or enforcement actions” an OFAC … Read more

OFAC Imposes Sanctions Restrictions on Myanmar’s State-Owned Oil and Gas Company

On October 31, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) imposed additional sanctions related to Myanmar. In particular, OFAC issued Directive 1 pursuant to Executive Order (“E.O.”) 14014, which imposes extensive sanctions restrictions on Myanma Oil and Gas Enterprise (“MOGE”). In addition, OFAC designated additional individuals and entities in … Read more

United States Departments of Treasury, Commerce, and Justice Issue “Tri-Seal” Compliance Note on Voluntary Self-Disclosure of Potential Violations

On Wednesday, July 26, 2023, the United States Department of Justice, Department of Commerce’s Bureau of Industry and Security (“BIS”), and Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a tri-seal compliance note (the “Note”) focusing on the voluntary self-disclosure policies that apply to U.S. sanctions, export controls, and other national security … Read more

OFAC Announces Sanctions on Illicit Gold Companies Funding Wagner Forces and Wagner Group Facilitator, New Burma Sanctions

On June 27, 2023, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) imposed sanctions on various entities and one individual connected to the Russian mercenary group PMC Wagner (“Wagner Group”) and its founder and owner Yevgeniy Prigozhin (“Prigozhin”). In this announcement, which can be read in full here, OFAC sanctioned … Read more

OFAC Enters Settlement Agreement With Swedbank Latvia for $3,430,900 Related to Apparent Violations of Crimea Sanctions

On June 20, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) entered a settlement agreement with Swedbank AS (Latvia) (“Swedbank Latvia”), a subsidiary of Swedbank AB, headquartered in Stockholm, Sweden. According to a press release, Swedbank Latvia agreed to pay $3,430,900 to settle its potential civil liability for 386 apparent … Read more

OFAC Announces New Designations of Companies Involved in the Production, Sale, and Shipment of Iranian Petrochemicals and Petroleum

On March 9, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned 39 entities. According to OFAC, the designated entities constitute a “significant ‘shadow banking’ network, one of several multi-jurisdictional illicit finance systems which grant sanctioned Iranian entities, such as Persian Gulf Petrochemical Industry Commercial Co. (PGPICC) and Triliance Petrochemical … Read more

Treasury Expands and Intensifies Sanctions Against Russia by Targeting Key Sectors, Evasion Efforts, and Military Supplies

On February 24, 2023, the one-year anniversary of the Russian invasion of Ukraine, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced significant actions that targeted Russia’s financial services sector, sanctions evasions, Russia’s military supply chain, and metals and mining sector. Under the authority of Executive Order 14024, OFAC targeted the … Read more

The United States and United Kingdom Issue Historic Joint Cyber Sanctions

On February 9, 2023, the United States, in coordination with the United Kingdom, designated seven individuals who are part of the Russia-based cybercrime gang Trickbot. The seven Russian individuals sanctioned—Vitaly Kovalev, Maksim Mikhailov, Valentin Karyagin, Mikhail Iskritskiy, Dmitry Pleshevskiy, Ivan Vakhromeyev and Valery Sedletski—were all alleged by the U.S. Treasury Department to be members of … Read more

OFAC Designates Board of Directors of Iranian UAV Manufacturer as SDNs

On February 3, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced sanctions on eight senior executives of Paravar Pars Company (Paravar Pars), an Iran-based firm that was previously sanctioned by the United States and European Union for manufacturing Shahed-series unmanned aerial vehicles (UAVs) for Iran’s Islamic Revolutionary Guard Corps … Read more