Companies should continue to expect an “aggressive” U.S. sanctions enforcement landscape heading into next year, and should consider increasing the amount of due diligence they undertake if they haven’t already, panelists said during an event last week about sanctions compliance.
The Office of Foreign Assets Control this week sanctioned five entities and one person involved with Russian and North Korean efforts to set up illegal payments mechanisms and help the countries evade sanctions. The designations target MRB Bank, based in the Russia-occupied Georgian region of South Ossetia, along with Russia-based TSMRBank, OOO; Russian Financial Corporation Bank JS; Stroytreyd LLC and Timer Bank, AO. OFAC also sanctioned Dmitry Yuryevich Nikulin, vice president of TSMRBank.
The U.S. and Canada this week sanctioned various Iranian government officials responsible for violence against the Iranian people, targeting members of the Islamic Revolutionary Guard Corps, officials with Iran’s Prisons Organization, and others responsible for suppressing protesters within the country or Iranians overseas.
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After initially facing scrutiny for helping to facilitate Russia-related transactions, Cypriot banks have made significant progress in improving their compliance programs in recent months and are now adhering to all U.S. sanctions rules, the country’s top banking industry officials said this week. They also said they face hurdles implementing some of the sanctions, including potential legal challenges from customers.
The Office of Foreign Assets Control last week added two Russian nationals and three Russian entities to its Specially Designated Nationals List and issued a new general license.
A new final rule released last week by the Office of Foreign Assets Control will clarify the agency’s process for issuing certain blocked property orders or orders that impose “less than full blocking” restrictions. The rule, effective Sept. 17, describes the three types of actions OFAC may take with respect to property or interests in property, the “forms of notice” that OFAC may use, and how parties affected by blocked property orders can contact the agency with “inquiries.” The agency said those affected by sanctions “should have an opportunity to understand the nature of OFAC’s action and its impact on their property or interests in property.” The rule also makes other minor revisions and clarifications to its sanctions regulations.
The Treasury Department this week sanctioned 16 Venezuelan officials that it said have ties to the Nicolas Maduro regime and who obstructed the country’s recent presidential elections (see 2407290044). The designated officials include leaders of the Maduro-aligned National Electoral Council and the Supreme Tribunal of Justice, which Treasury said “impeded a transparent electoral process and the release of accurate election results,” along with military, intelligence and government officials “responsible for intensifying repression through intimidation, indiscriminate detentions, and censorship.” The Biden administration will “continue to use our tools to hold Maduro and his cronies accountable and support the democratic aspirations of the Venezuelan people,” Deputy Treasury Secretary Wally Adeyemo said.
The Office of Foreign Assets Control sanctioned Cambodian businessman Ly Yong Phat, his company L.Y.P. Group Co., LTD, and the O‑Smach Resort for their ties to serious human rights abuses, including forced labor. The agency also designated Cambodia-based Garden City Hotel, Koh Kong Resort and Phnom Penh Hotel for being owned or controlled by Ly.
The Office of Foreign Assets Control unveiled an interim final rule this week that will extend the agency’s sanctions-related record-keeping requirements from five years to 10 years. The rule, effective in mid-March, will align the agency’s record-keeping rules with a similar expansion of the statute of limitations for civil and criminal violations of U.S. sanctions as part of a bill passed by Congress and signed into law earlier this year (see 2407220022 and 2404290071).