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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
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
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
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
On January 24, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control’s (“OFAC”) reportedly issued a specific license to Trinidad and Tobago to develop a major gas field located in Venezuelan territorial waters (the “Trinidad and Tobago License”). According to recent media reports, the Trinidad and Tobago License is “intended to enhance … Read more
On January 11, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a new Iran-related “Frequently Asked Question” (“FAQ”) (available here) regarding the implementation of Iran General License (“GL”) D-2, issued by OFAC on September 23, 2022. In addition to this new FAQ, OFAC also amended over twenty already published … Read more
On December 30, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control’s (“OFAC”) issued preliminary guidance on the implementation of the price cap policy for Russian-origin petroleum products (the “Petroleum Products Guidance”). The Petroleum Products Guidance is available here. The U.S. and other countries recently imposed a price cap related to Russian-origin … Read more
On December 9, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced sanctions on, among others, over 40 individuals and entities in North Korea (DPRK), El Salvador, Guatemala, Guinea, Iran, Mali, the Russian Federation, and China (PRC). In its announcement, OFAC stated that it utilized various tools and authorities—including Executive … Read more
On November 22, 2022, the U.S. Office of the Treasury’s Office of Foreign Assets Control (“OFAC”) released a Determination pursuant to Executive Order 14071, “Prohibiting New Investment in and Certain Services to the Russian Federation in Response to Continued Russian Federation Aggression.” The Determination states that E.O. 14071 will apply to trading and commodities brokering, … Read more
