Rachel Fiorill, former enforcement section chief at the Treasury Department's Office of Foreign Assets Control, joined Morrison Foerster as of counsel in the Washington, D.C., office, the firm announced. Fiorill most recently worked at Paul Weiss, where she advised clients on "economic sanctions, Bank Secrecy Act/Anti-Money Laundering," anti-corruption and export control proceedings. While at OFAC, Fiorill led investigations of hundreds of enforcement actions, serving as coordinator for the Enforcement Division's Ukraine, Russia and Syria-related investigations, Morrison Foerster said.
OFAC sanction activity
The Office of Foreign Assets Control sanctioned an international network that used a network of front companies to cover the delivery and sale of hundreds of millions of dollars’ worth of Iranian oil and petrochemical products from Iranian companies to East Asia, according to a July 6 press release. Two individuals, 13 entities, and two vessels were added to the Specially Designated Nationals list, according to OFAC's July 6 notice. The action follows an earlier action by OFAC on June 16, which designated members of an international sanctions-evasion network supporting Iranian petrochemical sales (see 2206160030). “While the U.S. is committed to achieving an agreement with Iran that seeks a mutual return to compliance with the Joint Comprehensive Plan of Action, we will continue to use all our authorities to enforce sanctions on the sale of Iranian petroleum and petrochemicals,” Undersecretary of the Treasury for Terrorism and Financial Intelligence Brian Nelson said.
The Office of Foreign Assets Control this week amended the Global Terrorism Sanctions Regulations to implement a Sept. 9, 2019, counterterrorism executive order. The amendments, which take effect July 1, implement the provisions of executive order 13886, “Modernizing Sanctions To Combat Terrorism” that amended sections 1(a) and 5 of Executive Order 13224. The change blocks all property and interests in property that are in the U.S. of persons listed in the amended Annex to E.O. 13224, foreign persons determined by the secretary of state to have committed or have attempted to commit acts of terrorism. It also makes certain "technical and conforming changes" to the regulations.
The Office of Foreign Assets Control on June 17 sanctioned Empresa Nicaraguense de Minas (ENIMINAS), Nicaragua’s state-owned mining company, and Ruy Lopez Delgado, the president of its board of directors. OFAC said the government has used ENIMINAS to solidify its control over Nicaragua’s mining sector and enrich government officials.
The Office of Foreign Assets Control sanctioned a network of Iranian petrochemical producers, as well as front companies in China and the United Arab Emirates. The front companies support Triliance and PCC, which broker sales of Iranian petrochemicals to China and East Asia, circumventing sanctions, OFAC said in a June 16 press release. The agency sanctioned two people and nine entities.
The Office of Foreign Assets Control is soliciting comments concerning information collection activities required by the Iranian Financial Sanctions Regulations Report on Closure by U.S. Financial Institutions of Correspondent Accounts and Payable-Through Accounts. Comments are due by Aug. 15.
U.S.-based Hygienic Dress League Corp said it may have violated U.S. sanctions, according to a June 9 SEC filing. The company, which operates in the non-fungible-tokens sector, said it recently submitted a voluntary self-disclosure to the Office of Foreign Assets Control after it may have allowed its software to be downloaded by people or entities located in territories subject to U.S. trade embargoes. After learning of the potential violations, the company began an “internal review” and took “remedial action designed to prevent similar activity from occurring in the future,” the filing said. The disclosure is still under review by OFAC.
Amid the rapid pace of Russia-related sanctions and export controls, regulators around the world are sometimes struggling or unwilling to provide timely and clear answers to industry questions about the trade restrictions, lawyers said. The issue is especially problematic in Europe, they said, where sanctions guidance may differ among the 27 EU member states and U.K. general licenses can be delayed or unhelpful.
A recent increase in U.S. sanctions against ransomware actors has helped to slow the effectiveness of cyberattackers and limit their profits, witnesses told the Senate Committee on Homeland Security and Governmental Affairs June 7. But the U.S. can do more to counter ransomware activity, they said, including working closer with allies to track ransomware payments and collecting better information from industry.
The Office of Foreign Assets Control published a new frequently asked question and updated two other FAQs related to its Russia sanctions. New FAQ 1055 clarifies how and whether Russia-related investment restrictions apply to the lending of funds or the purchasing of an equity interest in entities located outside Russia.