This newsletter is a listing of the latest changes in export control regulations through April 30, 2022. The newsletter is provided as a complimentary service to assist exporters with their ITAR and EAR export compliance responsibilities. It provides a summary of recent changes to export control regulations or other regulatory matters of interest that may impact your company’s international trade and export compliance functions. Call us at 703-847-5801 or email info@fdassociates.net with questions or comments.
See also our “Latest Sanctions Fines & Penalties” section below for an update on companies and persons denied export privileges by the United States Government.
REGULATORY UPDATES
The President
The President Designated Colombia As A Major Non-NATO Ally
April 21, 2022: The President, in accordance with section 517 of the Foreign Assistance Act of 1961, as amended (22 U.S.C. 2321k), provided notice of his intent to designate Colombia as a Major Non-NATO Ally in recognition of the importance of the U.S.-Colombia relationship and Colombia’s crucial contributions to regional and international security.
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Department of State, Directorate of Defense Trade Controls (DDTC)
DDTC Name And Address Changes Posted To Website
April 1 through 22, 2022: The Directorate of Defense Trade Controls (DDTC) posted the following name and/or address changes on its website at
- Change in Name from RFEL Ltd. to Rheinmetall Electronics UK Ltd., due to corporate rebranding;
- Change in Name from Flightline Electronics, Inc., to Undersea Sensor Systems, Inc., due to corporate merger with Undersea Sensor Systems, Inc.;
- Change in Address for ITOCHU Aviation Co., Ltd. Nagoya Branch from 5-28, Meieki 4-chome, Nakamura-ku, Nagoya 450-0002 Japan to 7-1, Meieki 4-chome, Nakamura-ku, Nagoya 450-6215 Japan;
- Change in Address for Sonovision Canada Inc., from 85 Albert Street, Suite 400, Ottawa, Ontario K1P 6A4, Canada to 179 Colonnade Rd. South, Unit 100, Nepean, Ontario K2E 7J4, Canada; and
- Change in Name from Sysco AS to Cegal AS due to corporate merger.
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Department of Commerce – Bureau of Industry and Security (BIS)
BIS Excludes Iceland, Liechtenstein, Norway And Switzerland From The Russia/Belarus Foreign-Produced Product Rule
April 8, 2022: 87 Fed. Reg. 21554: The U.S. Department of Commerce, Bureau of Industry and Security (BIS), established highly restrictive license requirements and policies for certain transactions involving Russia and Belarus under the Export Administration Regulations (EAR). These restrictive licensing requirements impact foreign parties who use U.S. manufacturing equipment and aids in the production of items sold to Russia and Belarus. Refer to the Foreign Direct Product rule at the EAR Part 734.9.
To recognize partner countries implementing substantially similar export controls on Russia and Belarus, the Department of Commerce published a list of countries excluded from the Foreign Direct Product rule related to foreign-produced items. In this rule, the Department of Commerce adds Iceland, Liechtenstein, Norway, and Switzerland to the list of excluded countries.
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The Department of Justice, Bureau of Alcohol, Tobacco, Firearms and Explosives
ATF Revised Definitions For “Firearm Frame Or Receiver” And “Frame Or Receiver”
April 26, 2022: 87 Fed. Reg. 24625: The Department of Justice (Department) is amending Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF) regulations to remove and replace the regulatory definitions of “firearm frame or receiver” and “frame or receiver” because the current regulations fail to capture the full meaning of those terms. The Department is also amending ATF's definitions of “firearm” and “gunsmith” to clarify the meaning of those terms, and to provide definitions of terms such as “complete weapon,” “complete muffler or silencer device,” “multi-piece frame or receiver,” “privately made firearm,” and “readily” for purposes of clarity given advancements in firearms technology. Further, the Department is amending ATF's regulations on marking and recordkeeping that are necessary to implement these new or amended definitions. See the revised definitions at: https://www.federalregister.gov/documents/2022/04/26/2022-08026/definition-of-frame-or-receiver-and-identification-of-firearms
| LATEST SANCTIONS FINES & PENALTIES |
This section of our newsletter provides information on the latest sanctions, fines, and penalties for export violations or matters of non-compliance with the ITAR or EAR issued by the US government enforcement agencies. It is provided as a service to exporters and associates of FD Associates to remind them of the importance of extreme due diligence in all international trade and export compliance matters, particularly those involving exports subject to the ITAR or the EAR. Don't let this happen to you or your company! Call us with questions or concerns at 703-847-5801 or email info@fdassociates.net.
Sanctions
The President
April 6, 2022: The President issued E.O. of April 6, 2022, “Prohibiting New Investment in and Certain Services to the Russian Federation in Response to Continued Russian Federation Aggression,” to ban all new investment in the Russian Federation by U.S. persons, wherever located, as well as the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of any category of services as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State, to any person located in the Russian Federation. These prohibitions follow recently issued Executive Orders 14066 and 14068, which prohibit certain imports and exports involving Russia, and are consistent with commitments made by the G7 leaders to ensure that our citizens are not underwriting Putin’s war.
https://home.treasury.gov/news/press-releases/jy0705 and https://www.whitehouse.gov/briefing-room/presidential-actions/2022/04/06/prohibiting-new-investment-in-and-certain-services-to-the-russian-federation-in-response-to-continued-russian-federation-aggression/
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April 6, 2022: The White House issued a Fact Sheet on the United States, G7, and EU sanctions on Russia. The U.S., with the G7 and the European Union, will continue to impose severe and immediate economic costs on the Putin regime for its atrocities in Ukraine, including in Bucha. The United States, G7, and EU will document and share information on these atrocities and use all appropriate mechanisms to hold accountable those responsible. As one part of this effort, the United States is announcing devastating economic measures to ban new investment in Russia and impose the most severe financial sanctions on Russia’s largest bank and several of its most critical state-owned enterprises and on Russian government officials and their family members. These sweeping financial sanctions follow White House action earlier to cut off Russia’s frozen funds in the United States to make debt payments. Importantly, these measures are designed to reinforce each other to generate intensifying impact over time.
The United States and more than 30 allies and partners across the world have levied the most impactful, coordinated, and wide-ranging economic restrictions in history. Experts predict Russia’s GDP will contract up to 15 percent this year, wiping out the last fifteen years of economic gains. Inflation is already spiking above 15 percent and is forecast to accelerate higher. More than 600 private sector companies have already left the Russian market. Supply chains in Russia have been severely disrupted. Russia will likely lose its status as a major economy, and it will continue a long descent into economic, financial, and technological isolation. Compared to last year, U.S. exports to Russia of items subject to the new export controls have decreased 99 percent by value – and the power of these restrictions will compound over time as Russia draws down any remaining stockpiles of spare parts for certain planes, tanks, and other resources needed for Putin’s war machine. As long as Russia continues its brutal assault on Ukraine, the United States, G7 and EU will stand unified with our allies and partners in imposing additional costs on Russia for its actions. To review the complete Fact Sheet, please go to the following link:
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April 6, 2022: 87 Fed. Reg. 20999: The President issued Executive Order 14071, which prohibits the following new investment in and certain services to the Russian Federation in response to continued Russian Federation aggression:
(i) new investment in the Russian Federation by a United States person, wherever located;
(ii) the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of any category of services as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State, to any person located in the Russian Federation; and
(iii) any approval, financing, facilitation, or guarantee by a United States person, wherever located, of a transaction by a foreign person where the transaction by that foreign person would be prohibited by this section if performed by a United States person or within the United States.
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April 22, 2022: 87 Fed. Reg. 24265: The policies and actions of the Government of the Russian Federation to continue the premeditated, unjustified, unprovoked, and brutal war against Ukraine constitute a national emergency by reason of a disturbance or threatened disturbance of international relations of the United States. In order to address this national emergency and secure the observance of the rights and obligations of the United States the President of the United States authorized the Secretary of Homeland Security (Secretary) to make and issue such rules and regulations as the Secretary may find appropriate to regulate the anchorage and movement of Russian-affiliated vessels, and delegate to the Secretary the President’s authority to approve such rules and regulations, as authorized by the Magnuson Act. Specifically, the President of the United States prohibits Russian-affiliated vessels from entering into United States ports. https://www.federalregister.gov/documents/2022/04/22/2022-08872/declaration-of-national-emergency-and-invocation-of-emergency-authority-relating-to-the-regulation
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The U.S. Department of State:
The U.S. Department of State established the Bureau of Cyberspace and Digital Policy, which leads and coordinates the Department of State’s work on cyberspace and digital diplomacy to encourage responsible state behavior in cyberspace and advance policies that protect the integrity and security of the infrastructure of the Internet, serve U.S. interests, promote competitiveness, and uphold democratic values. The Bureau of Cyberspace and Digital Policy addresses the national security challenges, economic opportunities, and values considerations presented by cyberspace, digital technologies, and digital policy and promotes standards and norms that are fair, transparent, and support our values.
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April 6, 2022: 87 Fed. Reg. 20029: Acting under the authority of and in accordance with section 1(a)(ii)(A) of E.O. 13224 of September 23, 2001, as amended by E.O. 13268 of July 2, 2002, E.O. 13284 of January 23, 2003, and E.O. 13886 of September 9, 2019, (“E.O. 13224”), I hereby determine that the person known as Katibat al Tawhid wal Jihad (also known as KTJ, Khatiba al-Tawhid wal-Jihad, Jannat Oshiklari, and Tawhid and Jihad Brigade) is a foreign person that has committed and poses a significant risk of committing acts of terrorism that threaten the security of U.S. nationals or the national security, foreign policy, or economy of the United States.
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April 7, 2022: The U.S. Department Of State targets Russia’s largest shipbuilding company, subsidiaries, and board members. United Shipbuilding Corporation (USC) is a major Russian State-Owned Enterprise (SOE) responsible for developing and building the Russian Navy’s warships. USC is responsible for the construction of almost all of Russia’s warships, as well as those built for foreign customers. Along with re-designating USC, the Department of State designated 28 subsidiaries and eight board members. These actions were also taken pursuant to E.O. 14024. See the entry below for OFAC’s designation of this entity and persons as Specially Designated Nationals and Blocked Persons.
https://www.state.gov/additional-state-department-designations-targeting-russian-state-owned-defense-shipbuilding-enterprise/
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Department of Commerce, Bureau of Industry and Security (BIS)
April 4, 2022: 87 Fed. Reg. 20295: In response to the Russian Federation's (Russia's) further invasion of Ukraine on February 24, 2022, the Department of Commerce, Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 120 entities under 120 entries to the Entity List. These 120 entities have been determined by the U.S. Government to be acting contrary to the national security interests or foreign policy of the United States and are listed on the Entity List under the destinations of Belarus and Russia.
The following entities from Belarus were added to the Entity List:
- 140 Repair Plant JSC;
- 558 Aircraft Repair Plant JSC;
- 2566 Radioelectronic Armament Repair Plant JSC;
- AGAT—Control Systems—Managing Company of Geoinformation Control Systems Holding JSC;
- Agat-Electromechanical Plant OJSC;
- AGAT-SYSTEM;
- ATE-Engineering LLC;
- BelOMO Holding;
- Belspetsvneshtechnika SFTUE;
- BSVT-New Technologies;
- CJSC Beltechexport;
- Department of Internal Affairs of the Gomel Region Executive Committee;
- Internal Troops of The Ministry of Internal Affairs of the Republic of Belarus;
- JSC Transaviaexport Airlines;
- KGB Alpha; Kidma Tech OJSC;
- Minotor-Service; Minsk Wheeled Tractor Plant;
- Oboronnye Initsiativy LLC;
- OJS KB Radar Managing Company;
- Peleng JSC;
- State Authority for Military Industry of the Republic of Belarus;
- State Security Committee of the Republic of Belarus; and
- Volatavto OJSC.
The following entities from Russia were added to the Entity List:
- 5th Shipyard;
- Alagir Resistor Factory;
- All-Russian Scientific-Research Institute Etalon JSC;
- Almaz JSC;
- Dolgoprudniy Design Bureau of Automatics;
- Electronic Computing Technology Scientific-Research Center;
- Electrosignal JSC;
- Inteltech PJSC;
- Joint Stock Company NPO Elektromechaniki;
- Kulon Scientific-Research Institute JSC;
- Lutch Design Office JSC;
- Meteor Plant JSC;
- Moscow Communications Research Institute JSC;
- Moscow Order of the Red Banner of Labor Research Radio Engineering Institute JSC;
- Omsk Production Union Irtysh JSC;
- Omsk Scientific-Research Institute of Instrument Engineering JSC;
- Optron JSC;
- Polyot Chelyabinsk Radio Plant JSC;
- Pskov Distance Communications Equipment Plant;
- Radiozavod JSC;
- Razryad JSC;
- Research Production Association Mars;
- Ryazan Radio-Plant;
- Scientific-Production Association and Scientific-Research Institute of Radio-Components;
- Scientific-Production Enterprise Almaz JSC;
- Scientific-Production Enterprise “Kant”;
- Scientific Production Enterprise “Radiosviaz”;
- Scientific-Production Enterprise “Svyaz”;
- Scientific-Production Enterprise Volna;
- Scientific-Production Enterprise Vostok JSC;
- Scientific-Research Institute “Argon”;
- Scientific-Research Institute of Automated Systems and Communications Complexes Neptune JSC; Scientific Research Institute of Communication Management Systems;
- Scientific Research Institute Ferrite-Domen;
- Special Design and Technical Bureau for Relay Technology;
- Tactical Missile Corporation, 711 Aircraft Repair Plant (711 ARZ);
- Tactical Missile Corporation, AO GNPP “Region”;
- Tactical Missile Corporation, AO TMKB “Soyuz”;
- Tactical Missile Corporation, Azov Optical and Mechanical Plant;
- Tactical Missile Corporation, “Central Design Bureau of Automation”;
- Tactical Missile Corporation, Concern “MPO—Gidropribor”;
- Tactical Missile Corporation, Joint Stock Company Avangard;
- Tactical Missile Corporation, Joint Stock Company Concern Granit-Electron;
- Tactical Missile Corporation, Joint Stock Company Elektrotyaga;
- Tactical Missile Corporation, Joint Stock Company GosNIIMash;
- Tactical Missile Corporation JSC “KRASNY GIDROPRESS”;
- Tactical Missile Corporation, Joint Stock Company PA Strela;
- Tactical Missile Corporation, Joint Stock Company “Plant Dagdiesel”;
- Tactical Missile Corporation, Joint Stock Company Plant Kulakov;
- Tactical Missile Corporation, Joint Stock Company Ravenstvo;
- Tactical Missile Corporation, Joint Stock Company Ravenstvo-service;
- Tactical Missile Corporation, Joint-Stock Company “Research Center for Automated Design”;
- Tactical Missile Corporation, Joint Stock Company “Salute”;
- Tactical Missile Corporation, Joint Stock Company Saratov Radio Instrument Plant;
- Tactical Missile Corporation Joint Stock Company “Scientific Research Institute of Marine Heat Engineering”;
- Tactical Missile Corporation, Joint Stock Company Severny Press;
- Tactical Missile Corporation, Joint Stock Company “State Machine Building Design Bureau “Vympel” By Name I.I. Toropov”;
- Tactical Missile Corporation, Joint Stock Company “URALELEMENT”;
- Tactical Missile Corporation, KB Mashinostroeniya;
- Tactical Missile Corporation, NPO Electromechanics;
- Tactical Missile Corporation, NPO Lightning;
- Tactical Missile Corporation, Petrovsky Electromechanical Plant “Molot”;
- Tactical Missile Corporation, PJSC ANPP Temp Avia;
- Tactical Missile Corporation, PJSC “MBDB ISKRA”;
- Tactical Missile Corporation, Raduga Design Bureau;
- Tactical Missile Corporation, RKB Globus;
- Tactical Missile Corporation, Smolensk Aviation Plant;
- Tactical Missile Corporation, TRV Engineering;
- Tactical Missile Corporation, Ural Design Bureau “Detal”;
- Tactical Missile Corporation, Zvezda-Strela Limited Liability Company;
- United Shipbuilding Corporation “Production Association Northern Machine Building Enterprise”;
- 46th TSNII Central Scientific Research Institute;
- All Russia Scientific Research Institute of Optical Physical Measurements;
- Arzam Scientific Production Enterprise Temp Avia;
- Automated Procurement System for State Defense Orders, LLC;
- Engineering Center Moselectronproekt;
- Etalon Scientific and Production Association;
- Evgeny Krayushin;
- Far-East Factory Zvezda;
- Federal Center for Dual-Use Technology (FTsDT) Soyuz;
- Foreign Trade Association Mashpriborintorg; Ineko LLC;
- Informakustika JSC;
- Institute of High Energy Physics;
- Institute of Theoretical and Experimental Physics;
- ISE SO RAN Institute of High-Current Electronics;
- JSC Energiya, Kaluga Scientific-Research Institute of Telemechanical Devices JSC;
- OJSC Pella Shipyard;
- Scientific Production Center Vigstar JSC;
- Scientific-Production Enterprise Salyut JSC;
- Scientific-Research Institute and Factory Platan;
- Special Design Bureau Salute JSC;
- Tambov Plant (TZ) “October”;
- Turayev Machine Building Design Bureau Soyuz; and
- Zhukovskiy Central Aerohydrodynamics Institute (TsAGI).
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April 7, 2022: The U.S. Department of Commerce, Bureau of Industry and Security (BIS) issued orders denying the export privileges of three Russian Airlines – Aeroflot, Azur Air, and UTair – due to ongoing export violations related to comprehensive export controls on Russia imposed by the Commerce Department. These three Temporary Denial Orders (TDOs) terminate the right of these airlines to participate in transactions subject to the Export Administration Regulations (EAR), including exports and reexports from the United States. These TDOs are issued for 180-days and may be renewed. https://www.commerce.gov/news/press-releases/2022/04/bis-takes-enforcement-actions-against-three-russian-airlines-operating
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April 7, 2022: 87 Fed. Reg. 20295: In response to the Russian Federation's (Russia's) further invasion of Ukraine on February 24, 2022, the Department of Commerce is amending the Export Administration Regulations (EAR) by adding 120 entities under 120 entries to the Entity List. These 120 entities have been determined by the U.S. Government to be acting contrary to the national security interests or foreign policy of the United States and will be listed on the Entity List under the destinations of Belarus and Russia. See the following link for a listing of the 120 entities added to the Entity List. https://www.federalregister.gov/documents/2022/04/07/2022-07284/additions-of-entities-to-the-entity-list
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April 8, 2022: 87 Fed. Reg. 22130: In response to the Russian Federation’s (Russia) ongoing aggression in Ukraine following its further invasion of the country, as substantially enabled by Belarus, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) expanded license requirements for Russia and Belarus under the Export Administration Regulations (EAR) to all items on the Commerce Control List (CCL), which added CCL Categories 0 – 2 to previous license requirements for CCL Categories 3 - 9. It also removes license exception eligibility for aircraft registered in, owned or controlled by, or under charter or lease by Belarus or a national of Belarus. https://www.bis.doc.gov/index.php/documents/federal-register-notices-1/2962-expansion-russia-and-belarus-rin-0694-ai83-4142022-effec482022-2022-07937/file
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April 14, 2022: The U.S. Commerce Department, through its Bureau of Industry and Security (BIS), publicly identified 10 additional aircraft likely in violation of U.S. export controls, including the first seven Belarusian owned/operated commercial aircraft identified since restrictions on Belarus were tightened via regulation effective on April 8, 2022. BIS is also updating the tail numbers of 32 planes already on the list to account for the planes’ purported re-registration in Russia. BIS has also authorized two planes to leave Russia and they will be removed from the list. The aircraft identified on the list have flown into Russia and/or Belarus in apparent violation of the Export Administration Regulations (EAR). See a list of aircraft at the following link:
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April 20, 2022: The U.S. Department of Commerce's Bureau of Industry and Security (BIS) denied the export privileges of Arnoldo Vidaurri (Vidaurri). Vidaurri was convicted of violating 18 U.S.C. § 554(a) for fraudulently and knowingly exporting and sending, from the United States to Mexico, two Ruger LCP 380 pistols and 100 rounds of ammunition, without a Department of State export license or other written authorization, in violation of 18 U.S.C. § 554.
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Department of the Treasury, Office of Foreign Assets Control (OFAC)
April 1, 2022: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned five entities for providing support to the Democratic People’s Republic of Korea’s (DPRK), a.k.a. North Korea, development of weapons of mass destruction (WMD) and ballistic missile programs in violation of multiple United Nations Security Council resolutions (UNSCRs).
The following entities have been added to OFAC's SDN List:
- Hapjanggang Trading Corporation;
- Korea Rounsan Trading Corporation;
- Ministry of Rocket Industry;
- Sungnisan Trading Corporation; And
- Unchon Trading Corporation.
https://home.treasury.gov/news/press-releases/jy0695 and https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220401
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April 5, 2022: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned the world’s largest and most prominent darknet market, Hydra Market (Hydra), in a coordinated international effort to disrupt the proliferation of malicious cybercrime services, dangerous drugs, and other illegal offerings available through the Russia-based site. The operation targeting Hydra was a collaborative initiative joined by the U.S. Department of Justice, Federal Bureau of Investigations, Drug Enforcement Administration, Internal Revenue Service Criminal Investigation, and Homeland Security Investigations. This action was enhanced by international cooperation with the German Federal Criminal Police, who shut down Hydra servers in Germany and seized $25 million worth of bitcoin.
The following entities have been added to OFAC's SDN List:
- Garantex Europe Ou of Estonia and Russia;
- Hydra Market including its various websites of Russia. See the following links for the list of websites.
https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220405 and https://home.treasury.gov/news/press-releases/jy0701
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April 6, 2022: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) took major steps to degrade the economy of the Russian Federation in response to Russia’s continued brutal war against Ukraine and atrocities against Ukrainian citizens. Treasury is imposing full blocking sanctions on Sberbank, Russia’s largest state-owned bank, and Alfa-Bank, Russia’s largest private bank. Treasury is also targeting family members of President Vladimir Putin (Putin) and Foreign Minister Sergey Lavrov (Lavrov), as well as Russian Security Council members who are complicit in the war against Ukraine.
OFAC has issued Russia-related General License 8B, General License 9B, General License 10B, General License 21, General License 22, and General License 23, as described below.
General License 8B: All transactions prohibited by Executive Order (E.O.) 14024 involving one or more of the following entities that are related to energy are authorized, through 12:01 a.m. eastern daylight time, June 24, 2022:
(1) State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank; (2) Public Joint Stock Company Bank Financial Corporation Otkritie;
(3) Sovcombank Open Joint Stock Company;
(4) Public Joint Stock Company Sberbank of Russia;
(5) VTB Bank Public Joint Stock Company;
(6) Joint Stock Company Alfa-Bank;
(7) Any entity in which one or more of the above persons own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest; or
(8) the Central Bank of the Russian Federation.
For the purposes of this general license, the term “related to energy” means the extraction, production, refinement, liquefaction, gasification, regasification, conversion, enrichment, fabrication, transport, or purchase of petroleum, including crude oil, lease condensates, unfinished oils, natural gas liquids, petroleum products, natural gas, or other products capable of producing energy, such as coal, wood, or agricultural products used to manufacture biofuels, or uranium in any form, as well as the development, production, generation, transmission, or exchange of power, through any means, including nuclear, thermal, and renewable energy sources.
https://home.treasury.gov/system/files/126/russia_gl8b.pdf
General License 9B: All transactions prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR), that are ordinarily incident and necessary to dealings in debt or equity of one or more of the following entities issued prior to February 24, 2022 (“Tranche 1 debt or equity”) are authorized through 12:01 a.m. eastern daylight time, May 25, 2022, provided that any divestment or transfer of, or facilitation of divestment or transfer of, Tranche 1 debt or equity must be to a non-U.S. person:
(i) State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank; (ii) Public Joint Stock Company Bank Financial Corporation Otkritie;
(iii) Sovcombank Open Joint Stock Company;
(iv) Public Joint Stock Company Sberbank of Russia;
(v) VTB Bank Public Joint Stock Company; or
(vi) Any entity in which one or more of the above entities own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest.
All transactions prohibited by the RuHSR that are ordinarily incident and necessary to dealings in debt or equity of Joint Stock Company Alfa-Bank (“Alfa-Bank”) or any entity in which Alfa-Bank owns, directly or indirectly, a 50 percent or greater interest, issued prior to April 6, 2022 (“Alfa-Bank debt or equity”) are authorized through 12:01 a.m. eastern daylight time, June 30, 2022, provided that any divestment or transfer of, or facilitation of divestment or transfer of, Alfa-Bank debt or equity must be to a non-U.S. person.
https://home.treasury.gov/system/files/126/russia_gl9b.pdf
General License 10B: All transactions prohibited by the RuHSR that are ordinarily incident and necessary to the wind down of derivative contracts entered into prior to 4:00 p.m. eastern standard time, February 24, 2022, that:
(i) include one of the following entities (together, the “Tranche 1 entities”) as a counterparty or
(ii) are linked to debt or equity of a Tranche 1 entity are authorized through 12:01 a.m. eastern daylight time, May 25, 2022, provided that any payments to a blocked person are made into a blocked account:
(i) State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank;
(ii) Public Joint Stock Company Bank Financial Corporation Otkritie;
(iii) Sovcombank Open Joint Stock Company;
(iv) Public Joint Stock Company Sberbank of Russia;
(v) VTB Bank Public Joint Stock Company; or
(vi) Any entity in which one or more of the above entities own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest.
All transactions prohibited by the RuHSR that are ordinarily incident and necessary to the wind down of derivative contracts entered into prior to 4:00 p.m. eastern daylight time, April 6, 2022, that:
(i) include Joint Stock Company Alfa-Bank (“Alfa-Bank”) or any entity in which Alfa-Bank owns, directly or indirectly, a 50 percent or greater interest (collectively, “Alfa-Bank entities”) as a counterparty; or
(ii) are linked to debt or equity of an Alfa-Bank entity are authorized through 12:01 a.m. eastern daylight time, June 30, 2022, provided that any payments to a blocked person are made into a blocked account. (3) Debits to accounts on the books of a U.S. financial institution are authorized to the extent ordinarily incident and necessary to effect the transactions authorized in this general license.
All transactions prohibited by Directive 4 under Executive Order (E.O.) 14024, Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation, that are ordinarily incident and necessary to the wind-down of derivative contracts, repurchase agreements, or reverse repurchase agreements entered into prior to 12:01 a.m. eastern standard time, March 1, 2022, that include the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation (collectively, “Directive 4 entities”) as a counterparty are authorized through 12:01 a.m. eastern daylight time, May 25, 2022. https://home.treasury.gov/system/files/126/russia_gl10b.pdf
General License 21: U.S. persons are authorized to engage in all transactions ordinarily incident and necessary to the wind-down of Sberbank CIB USA, Inc., or any entity in which Sberbank CIB USA, Inc. owns, directly or indirectly, a 50 percent or greater interest, that are prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR), including the processing and payment of salaries, severance, and expenses; payments to vendors and landlords; and closing of accounts, through 12:01 a.m. eastern daylight time, June 7, 2022. https://home.treasury.gov/system/files/126/russia_gl21.pdf
General License 22: All transactions ordinarily incident and necessary to the wind-down of transactions involving Public Joint Stock Company Sberbank of Russia (“Sberbank”) or any entity in which Sberbank owns, directly or indirectly, a 50 percent or greater interest that are prohibited by Executive Order (E.O.) 14024 are authorized through 12:01 a.m. eastern daylight time, April 13, 2022. https://home.treasury.gov/system/files/126/russia_gl22.pdf
General License 23: All transactions ordinarily incident and necessary to the wind-down of transactions involving Joint Stock Company AlfaBank (“Alfa-Bank”) or any entity in which Alfa-Bank owns, directly or indirectly, a 50 percent or greater interest that is prohibited by Executive Order 14024 are authorized through 12:01 a.m. eastern daylight time, May 6, 2022. https://home.treasury.gov/system/files/126/russia_gl23.pdf
The following individuals have been added to OFAC's SDN List:
- Katerina Vladimirovna Tikhonova, Vladmir Putin’s daughter, of Russia;
- Maria Vladimirovna Vorontsova, Vladmir Putin’s daughter, of Russia;
- Beglov, Aleksandr Dmitrievich of Russia and Azerbeijan;
- Bulavin, Vladimir Ivanovich of Russia;
- Chayka, Yuriy Yakovlevich of Russia;
- Chuychenko, Konstantin Anatolyevich of Russia;
- Gutsan, Aleksandr Vladimirovich of Russia;
- Komarov, Igor Anatolyevich of Russia;
- Lavrova, Maria Aleksandrovna, Sergey Lavrov’s wife, of Russia;
- Medvedev, Dmitry Anatolievich of Russia;
- Mishustin, Mikhail Vladimirovich of Russia;
- Nurgaliev, Rashid Gumarovich of Russia and Kazakhstan;
- Seryshev, Anatoliy Anatolievich of Russia;
- Siluanov, Anton Germanovich of Russia;
- Sobyanin, Sergey Semyonovich of Russia;
- Trutnev, Yuriy Petrovich of Russia;
- Ustinov, Vladimir Vasilyevich of Russia;
- Vaino, Anton Eduardovich of Russia;
- Vinokurova, Yekaterina Sergeyevna of Russia and the United States, Sergey Lavrov’s daughter;
- Yakushev, Vladimir Vladimirovich of Russia.
The following entities have been added to OFAC's SDN List:
- Alfa Capital Markets Ltd, of Cyprus;
- Alfa-Direct of Russia;
- Alfa-Forex LLC of Russia;
- Alfa-Lizing OOO of Russia;
- Amsterdam Trade Bank NV of The Netherlands;
- Arimero Holding Limited, of Cyprus;
- Auction Limited Liability Company of Russia;
- Bankruptcy Technology Center Limited Liability Company of Russia;
- Barus Limited Liability Company of Russia;
- IKS Joint Stock Company of Russia;
- Insurance Company Sberbank Insurance Limited Liability Company of Russia;
- Insurance Company Sberbank Life Insurance Limited Liability Company of Russia;
- Joint Stock Company Alfa-Bank of Russia;
- Joint Stock Company Business Environment of Russia;
- Joint Stock Company Loyalty Programs Center of Russia;
- Joint Stock Company Raschetniye Resheniya of Russia;
- Joint Stock Company Sberbank of Russia and the Ukraine;
- Joint Stock Company Sberbank Automated Trade System of Russia;
- Joint Stock Company Sberbank Leasing of Russia;
- Joint Stock Company Sberbank Private Pension Fund of Russia;
- Joint Stock Company Sberbank Technologies of Russia;
- Joint Stock Company Strategy Partners Group of Russia;
- Joint Stock Company United Credit Bureau of Russia;
- Limited Liability Company Active Business Consult of Russia;
- Limited Liability Company Digital Technologies of Russia;
- Limited Liability Company Korus Consulting CIS of Russia;
- Limited Liability Company Market Fund Administration of Russia;
- Limited Liability Company Promising Investments of Russia;
- Limited Liability Company Rutarget of Russia;
- Limited Liability Company Sberbank Capital of Russia;
- Limited Liability Company Sberbank CIB Holding of Russia;
- Limited Liability Company Sberbank Factoring of Russia;
- Limited Liability Company Sberbank Financial Company of Russia;
- Limited Liability Company Sberbank Insurance Broker of Russia;
- Limited Liability Company Sberbank Investments of Russia;
- Limited Liability Company Sberbank Real Estate Center of Russia;
- Limited Liability Company Sberbank Service of Russia;
- Limited Liability Company Yoomoney of Russia;
- Open Joint Stock Company BPS-Sberbank of Russia;
- Public Joint Stock Company Sberbank Of Russia of Russia;
- SB Securities SA, of Luxembourg;
- SBER Legal Limited Liability Company of Russia;
- SBER Vostok Limited Liability Partnership of Russia;
- Sberbank Europe AG, of Austria;
- Setelem Bank Limited Liability Company of Russia;
- Sovremennye TekhnologII Limited Liability Company of Russia;
- Subsidiary Bank Alfa-Bank JSC of Russia;
- Subsidiary Bank Sberbank Of Russia Joint Stock Company of Kazakhstan;
- Tekhnologii Kreditovaniya Limited Liability Company of Russia;
- Vydayushchiesya Kredity Microcredit Company Limited Liability Company of Russia.
The following vessels have been added to OFAC's SDN List:
- Lady Leila (UCGL) of Russia;
- Lady Rania (UBBO9) of Russia;
- Lady Sevda (UBWL7) of Russia;
- Sv Konstantin (UBUS4) of Russia;
- Sv Nikolay (UBTU6) of Russia.
https://home.treasury.gov/news/press-releases/jy0705 and https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220406 and https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220406_33
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April 7, 2022: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated Alrosa, a Russian state-owned enterprise (SOE) and the world’s largest diamond mining company, which is also responsible for 90 percent of Russia’s diamond mining capacity. The Department of State also redesignated Joint Stock Company United Shipbuilding Corporation (USC), as well as its subsidiaries and board members. USC is a Russian SOE that develops and constructs the majority of the Russian military’s warships, likely including many of those used to bombard Ukraine’s cities and harm Ukraine’s citizens. These actions were taken pursuant to Executive Order (E.O.) 14024. Through these designations, Treasury is cutting off additional sources of support and revenue for the Government of the Russian Federation (GoR) to wage its unprovoked war against Ukraine.
OFAC also issued Russia-related General License 9C, General License 10C, General License 21A, General License 24, and General License 25.
General License 9C: All transactions prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR), that are ordinarily incident and necessary to dealings in debt or equity of one or more of the following entities issued prior to February 24, 2022 (“Russian financial institution debt or equity”) are authorized through 12:01 a.m. eastern daylight time, May 25, 2022, provided that any divestment or transfer of, or facilitation of divestment or transfer of, Russian financial institution debt or equity must be to a non-U.S. person:
(i) State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank;
(ii) Public Joint Stock Company Bank Financial Corporation Otkritie;
(iii) Sovcombank Open Joint Stock Company;
(iv) Public Joint Stock Company Sberbank of Russia;
(v) VTB Bank Public Joint Stock Company; or
(vi) Any entity in which one or more of the above entities own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest.
https://home.treasury.gov/system/files/126/russia_gl9c.pdf
General License 10C: All transactions prohibited by the RuHSR, that are ordinarily incident and necessary to the wind down of derivative contracts entered into prior to 4:00 p.m. eastern standard time, February 24, 2022, that (i) include one of the following entities (collectively, the “Russian financial institution entities”) as a counterparty or (ii) are linked to debt or equity of a Russian financial institution entity are authorized through 12:01 a.m. eastern daylight time, May 25, 2022, provided that any payments to a blocked person are made into a blocked account:
(i) State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank;
(ii) Public Joint Stock Company Bank Financial Corporation Otkritie;
(iii) Sovcombank Open Joint Stock Company;
(iv) Public Joint Stock Company Sberbank of Russia;
(v) VTB Bank Public Joint Stock Company; or
(vi) Any entity in which one or more of the above entities own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest.
https://home.treasury.gov/system/files/126/russia_gl10c.pdf
General License 21A: U.S. persons are authorized to engage in all transactions ordinarily incident and necessary to the wind-down of Sberbank CIB USA, Inc. or Alrosa USA, Inc. (collectively, the “blocked entities”), or any entity in which the blocked entities own, directly or indirectly, a 50 percent or greater interest, that are prohibited by the RuHSR, including the processing and payment of salaries, severance, and expenses; payments to vendors and landlords; and closing of accounts, through 12:01 a.m. eastern daylight time, June 7, 2022.
https://home.treasury.gov/system/files/126/russia_gl21a.pdf
General License 24: All transactions ordinarily incident and necessary to the wind-down of transactions involving Public Joint Stock Company Alrosa (“Alrosa”) or any entity in which Alrosa owns, directly or indirectly, a 50 percent or greater interest that is prohibited by Executive Order 14024 are authorized through 12:01 a.m. eastern daylight time, May 7, 2022. https://home.treasury.gov/system/files/126/russia_gl24.pdf
General License 25: All transactions ordinarily incident and necessary to the receipt or transmission of telecommunications involving the Russian Federation that are prohibited by the RuHSR, are authorized. The exportation or reexportation, sale, or supply, directly or indirectly, from the United States or by U.S. persons, wherever located, to the Russian Federation of services, software, hardware, or technology incident to the exchange of communications over the internet, such as instant messaging, videoconferencing, chat and email, social networking, sharing of photos, movies, and documents, web browsing, blogging, web hosting, and domain name registration services, that is prohibited by the RuHSR, is authorized.
https://home.treasury.gov/system/files/126/russia_gl25.pdf
The following individuals have been added to OFAC's SDN List:
- Lavrishchev, Andrey Vasilyevich of Russia;
- Markelov, Vitaliy Anatolyevich of Russia;
- Poltavchenko, Georgiy Sergeyevich of Russia;
- Pospelov, Vladimir Yakovlevich of Russia;
- Rakhmanov, Aleksey Lvovich of Russia;
- Ryazantsev, Oleg Nikolayevich of Russia;
- Shestakov, Ilya Vasilyevich of Russia;
- Shishkin, Andrei Nikolaevich of Russia.
The following entities have been added to OFAC's SDN List:
- Almaz Central Marine Design Bureau Joint Stock Company of Russia;
- Baltic Shipyard JSC of Russia;
- Federal State Unitary Enterprise Kronshtadtskyy Morskoy Factory Minoborony Rossii of Russia;
- Joint Public Stock Company Nevskoe Design Bureau of Russia;
- Joint Stock Company 10 Ordena Trudovogo Krasnogo Znameni Dockyard of Russia;
- Joint Stock Company Admiralty Shipyards of Russia;
- Joint Stock Company Baltic Shipbuilding Plant Yantar of Russia;
- Joint Stock Company Central Design Bureau For Marine Engineering Rubin of Russia;
- Joint Stock Company Design Office For Shipbuilding Vympel of Russia;
- Joint Stock Company Khabarovsk Shipbuilding Yard of Russia;
- Joint Stock Company Northern Production Association Arktika of Russia;
- Joint Stock Company Production Association Northern Machine-Building Enterprise of Russia;
- Joint Stock Company Research Design And Technological Bureau Onega of Russia;
- Joint Stock Company Shipbuilding Plant Lotos of Russia;
- Joint Stock Company Shiprepairing Center Zvyozdochka of Russia;
- Joint Stock Company Sredne-Nevsky Shipyard of Russia;
- Joint Stock Company Sudoexport of Russia;
- Joint Stock Company Svetlovsky Enterprise Era of Russia;
- Joint Stock Company The St. Petersburg's Sea Bureau Of Mechanical Engineering Malachite of Russia;
- JSC 33 Shipyard of Russia;
- Limited Liability Company Kaspiyskaya Energiya Administration Office of Russia;
- Public Joint Stock Company Alrosa of Russia;
- Public Joint Stock Company Amursky Shipbuilding Plant of Russia;
- Public Joint Stock Company Krasnoye Sormovo Shipyard of Russia;
- Public Joint Stock Company Proletarsky Zavod of Russia;
- Public Joint Stock Company Shipbuilding Plant Severnaya Verf of Russia;
- Public Joint Stock Company Vyborg Shipyard of Russia;
- Severnoe Design Bureau Joint Stock Company of Russia;
- United Shipbuilding Corporation Jsc Aysberg Central Design Building of Russia.
https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220407 and https://home.treasury.gov/news/press-releases/jy0707
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April 11, 2022: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated seven individuals and one entity across four countries in the Western Balkans pursuant to Executive Order (E.O.) 14033. This is the second action OFAC has taken under E.O. 14033 targeting persons who threaten the stability of the region through corruption, criminal activity, and other destabilizing behavior. This action reinforces Treasury’s commitment to promoting accountability for actors in the Western Balkans region engaged in destabilizing and corrupt behavior. Such corrupt behavior undermines the rule of law and economic growth, and it deprives people in these countries of opportunities and stability.
The following individuals have been added to OFAC's SDN List:
- Gruevski, Nikola of North Macedonia;
- Marovic, Svetozar of Montenegro;
- Mijalkov, Sasho of North Macedonia;
- Ndroqi, Ylli Bahri of Alabania;
- Rakipi, Aqif of Albania;
- Sarajlic, Asim of Bosnia and Herzegovina;
- Tadic, Gordana of Bosnia and Herzegovina.
The following entity has been added to OFAC’s SDN List:
- C.I.C. KFT. of Hungary.
The following deletions have been made to OFAC’s SDN List:
- Arsenovic, Djojo of Bosnia-Herzegovin;
- Bala, Haradin of Serbia and Montenegro;
- Borovnica, Goran of the Balkans;
- Cengic, Hasan of Bosnia-Herzegovina;
- Deronjic, Miroslav of Bosnia-Herzegovina;
- Gashi, Sabit of Serbia and Montenegro;
- Hyseni, Xhemajl of Macedonia;
- Josipovic, Drago; of Bosnia-Herzegovina;
- Marinic, Zoran of Bosnia-Herzegovina;
- Mrksic, Milan of Croatia;
- Mucic, Zdravko of the Balkans;
- Musliu, Jonuz of Serbia and Montenegro;
- Nikolic, Drago of Bosnia-Herzegovina;
- Ojdanic, Dragoljub of Serbia and Montenegro;
- Rushiti, Sait of the Balkans;
- Ruxheti, Sait of the Balkans;
- Strugar, Pavle of Serbia and Montenegro;
- Talic, Momir of Bosnia-Herzegovina;
- Todorovic, Stevan of Bosnia-Herzegovina;
- Zelenovic, Dragan of the Balkans;
- Beara, Ljubisa of Bosnia and Herzegovina;
- Hadzic, Goran of Croatia.
https://home.treasury.gov/news/press-releases/jy0712 and https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220411
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April 11, 2022: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated the Kinahan Organized Crime Group (KOCG) along with seven of its key members, including its Irish leaders Christopher Vincent Kinahan Senior, Daniel Joseph Kinahan, Christopher Vincent Kinahan Junior, and three associated businesses pursuant to Executive Order (E.O.) 13581, “Blocking Property of Transnational Criminal Organizations,” as amended. Today’s action is the result of close collaboration between OFAC, the Drug Enforcement Administration, the U.S. Department of State, U.S. Customs and Border Protection, Ireland’s national police force (An Garda Síochána), the United Kingdom’s National Crime Agency, and the European Union Agency for Law Enforcement Cooperation.
The following individuals have been added to OFAC's SDN List:
- Clancy, Bernard Patrick of Spain; Dubai, United Arab Emirates; and Ireland;
- Dixon, Ian Thomas of the United Arab Emirates and Ireland;
- Kinahan Junior, Christopher Vincent of the United Arab Emirates and Ireland;
- Kinahan, Christopher Vincent of the United Arab Emirates, the United Kingdom, and Ireland;
- Kinahan, Daniel Joseph of the United Arab Emirates, Spain, the United Kingdom, and Ireland;
- Mcgovern, Sean Gerard of the United Arab Emirates and Ireland;
- Morrissey, John Francis of Spain and Ireland.
The following entities have been added to OFAC's SDN List:
- Ducashew General Trading LLC of the United Arab Emirates;
- Hoopoe Sports LLC of the United Arab Emirates;
- Kinahan Organized Crime Group of Ireland, the United Kingdom, Spain, The Netherlands, and the United Arab Emirates;
- Nero Drinks Company Limited of the United Kingdom and Spain.
https://home.treasury.gov/news/press-releases/jy0713 and https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220411_33
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April 12, 2022: The Department of the Treasury's Office of Foreign Assets Control (OFAC) issued Russia-related General License 26. This General License authorizes all transactions ordinarily incident and necessary to the wind-down of transactions involving Joint Stock Company SB Sberbank Kazakhstan or Sberbank Europe AG (collectively, “the blocked Sberbank subsidiaries”), or any entity in which the blocked Sberbank subsidiaries own, directly or indirectly, a 50 percent or greater interest, that are prohibited by Executive Order (E.O.) 14024 are authorized through 12:01 a.m. eastern daylight time, July 12, 2022.
https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220412
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April 14, 2022: The Department of the Treasury's Office of Foreign Assets Control (OFAC) made following changes to the SDN List:
- Lazarus Group was listed as a secondary sanctions risk: North Korea Sanctions Regulations, sections 510.201 and 510.210; Transactions Prohibited For Persons Owned or Controlled By U.S. Financial Institutions: North Korea Sanctions Regulations section 510.214. LAZARUS GROUP is a North Korean hacker group that is linked to the recent Ronin bridge hack.
https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220414 and https://news.bitcoin.com/ofac-update-claims-ronin-hack-is-tethered-to-north-koreas-hacker-syndicate-lazarus-group/
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April 19, 2022: The United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Russia-related General License 27 "Certain Transactions in Support of Nongovernmental Organizations’ Activities." General License 27 authorizes all transactions ordinarily incident and necessary to the activities described below by non-governmental organizations that are prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR), are authorized, provided that the only involvement of blocked persons is the processing of funds by financial institutions blocked pursuant to Executive Order (E.O.) 14024. (b) The activities are as follows:
(1) Activities to support humanitarian projects to meet basic human needs in Ukraine or the Russian Federation, including drought and flood relief; food, nutrition, and medicine distribution; the provision of health services; assistance for vulnerable or displaced populations, including individuals with disabilities and the elderly; and environmental programs;
(2) Activities to support democracy-building in Ukraine or the Russian Federation, including activities to support rule of law, citizen participation, government accountability, and transparency, human rights and fundamental freedoms, access to information, and civil society development projects;
(3) Activities to support education in Ukraine or the Russian Federation, including combating illiteracy, increasing access to education, international exchanges, and assisting education reform projects;
(4) Activities to support non-commercial development projects directly benefiting the people of Ukraine or the Russian Federation, including those related to health, food security, and water and sanitation; and (5) Activities to support environmental and natural resource protection in Ukraine or the Russian Federation, including the preservation and protection of threatened or endangered species, responsible and transparent management of natural resources, and the remediation of pollution or other environmental damage.
https://home.treasury.gov/system/files/126/russia_gl27.pdf and https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220419
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April 20, 2022: The Department of the Treasury's Office of Foreign Assets Control (OFAC) has issued Russia-related General License 28 and General License 29.
In addition, the following names have been added or updated to OFAC's list of Specially Designated Nationals.
General License 28: Authorizes all transactions involving Public Joint Stock Company Transkapitalbank (TKB), or any entity in which TKB owns, directly or indirectly, a 50 percent or greater interest, that are ultimately destined for or originating from Afghanistan and prohibited by Executive Order (E.O.) 14024 are authorized through 12:01 a.m. eastern daylight time, October 20, 2022. U.S. financial institutions are authorized to operate correspondent accounts on behalf of TKB, or any entity in which TKB owns, directly or indirectly, a 50 percent or greater interest, provided such accounts are used solely to effect transactions authorized in paragraph (a) of this general license. https://home.treasury.gov/system/files/126/russia_gl28.pdf
General License 29: Authorizes all transactions ordinarily incident and necessary to the wind-down of transactions involving Public Joint Stock Company Transkapitalbank (TKB), or any entity in which TKB owns, directly, or indirectly, a 50 percent or greater interest, that is prohibited by Executive Order (E.O.) 14024, are authorized through 12:01 a.m. eastern daylight time, May 20, 2022. https://home.treasury.gov/system/files/126/russia_gl29_0.pdf
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) also designated entities and individuals involved in attempts to evade sanctions imposed by the United States and its international partners on Russia. OFAC designated Russian commercial bank Transkapitalbank and a global network of more than 40 individuals and entities led by U.S.-designated Russian oligarch Konstantin Malofeyev, including organizations whose primary mission is to facilitate sanctions evasion for Russian entities. OFAC also designated companies operating in Russia’s virtual currency mining industry, reportedly the third-largest in the world. This is the first time Treasury has designated a virtual currency mining company.
The following individuals have been added to OFAC's SDN List:
- Alekseev, Mikhail Yurevich of Russia;
- Cherkasova, Nadia Narimanovna of Russia;
- Emelyanova, Svetlana Petrovna of Russia;
- Gadetskiy, Yevgeniy Yuryevich of Russia;
- Goldfinch, Paul Andrew of Russia and New Zealand;
- Golikov, Andrey Fedorovich of Russia;
- Karachinskiy, Anatoly Mikhailovich of Russia;
- Kolychev, Vladimir Vladimirovich of Russia;
- Kremleva, Irina Vladimirovna of Russia;
- Kupriyanov, Alexey Aleksandrovich of Russia;
- Kuzmin, Pavel Vladimirovich of Russia;
- Leshchenko, Mikhail Aleksandrovich of Russia;
- Levin, Dmitriy Olegovich of Russia;
- Malofeyev, Kirill Konstantinovich of Russia;
- Markov, Ilya Anatolyevich of Russia;
- Melikov, Nikita of Russia;
- Nechiporuk, Roman Viktorovich of Russia;
- Nesterenko, Tatyana Gennadevna of Russia;
- Nikolaev, Viktor Andreevich of Russia;
- Okulov, Aleksandr of Russia; Romania; United Arab Emirates; and Moldova;
- Rusanov, Sergey Georgievich of Russia;
- Samoylov, Artem of Russia;
- Simanovskiy, Alexey Yurevich of Russia;
- Subbotin, Alexey Anatolyevich of Russia;
- Titova, Elena Borisovna of Russia;
- Tyurina, Natalya Aleksandrovna of Russia;
- Yakushev, Mikhail Ilich of Russia;
- Yudayeva, Kseniya Valentinovna of Russia;
- Zadornov, Mikhail Mikhaylovich of Russia.
The following entities have been added to OFAC's SDN List:
- Agent De Asigurare Lider Asig Societate Cu Raspundere Limitata of Moldova;
- All-Russian Public Organization Society For The Promotion Of Russian Historical Development Tsargrad of Russia;
- Analiticheski Tsentr Katekhon OOO of Russia;
- Autonomous Noncommercial Organization For The Study And Development Of International Cooperation In The Economic Sphere International Agency Of Sovereign Development of Russia;
- Bitriver AG of Switzerland;
- Ekoferma Zareche OOO of Russia;
- Imenie Tsargrad OOO of Russia;
- Imperiya 19-31 OOO of Russia;
- Joint Stock Company Investtradebank of Russia;
- Joint Stock Company Marshal Global of Russia;
- Kontur OOO of Russia;
- Kurort Livadiya OOO of Russia;
- Kurort Tsargrad Spas-Teshilovo OOO of Russia;
- Limited Liability Company Russian Digital Solutions of Russia;
- Limited Liability Company Vladeks of Russia;
- Limited Liability Company Vladeks Kholding of Russia;
- MGI PTE LTD of Singapore;
- Okaf Trading Societatea Cu Raspundere Limitata of Moldova;
- OOO Bitriver Rus of Russia;
- OOO Bitriver-B of Russia;
- OOO Bitriver-K of Russia;
- OOO Bitriver-North of Russia;
- OOO Bitriver-Turma of Russia;
- OOO Everest Grup of Russia;
- OOO Management Company Bitriver of Russia;
- OOO Sibirskie Mineraly of Russia;
- OOO Torgovy Dom Asbest of Russia;
- OOO Tuvaasbest of Russia;
- Organizatia De Creditare Nebancara Lider Leasing SRL of Moldova;
- Proizvodstvenno-Stroitelnaya Kompaniya SNM of Russia;
- Public Joint Stock Company Transkapitalbank of Russia;
- Societatea Cu Raspundere Limitata Project Invest Company of Moldova;
- Spetsinvestservis OOO of Russia;
- Teshilovo OOO of Russia;
- Tsargrad OOO of Russia;
- Tsargrad Park OOO of Russia;
- Tsargrad-Kultura OOO of Russia;
- Tsargrad-Media OOO of Russia;
- Tureya OOO of Russia;
- Zareche-Oka OOO of Russia.
https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220420 and https://home.treasury.gov/news/press-releases/jy0731
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April 25, 2022: The Department of the Treasury's Office of Foreign Assets Control (OFAC) is issuing Ukraine-/Russia-related General License 13R and General License 15L. In addition, OFAC has updated several Frequently Asked Questions.
https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220425_33
General License 13R: Authorizes all transactions and activities otherwise prohibited by the Ukraine Related Sanctions Regulations, 31 CFR part 589 (URSR), that are ordinarily incident and necessary (1) to divest or transfer debt, equity, or other holdings in GAZ Group to a non-U.S. person, or (2) to facilitate the transfer of debt, equity, or other holdings in GAZ Group by a non-U.S. person to another non-U.S. person, are authorized through 12:01 a.m. eastern daylight time, May 25, 2022.
Authorizes all transactions and activities otherwise prohibited by the URSR that are ordinarily incident and necessary to (1) divest or transfer debt, equity, or other holdings in GAZ Group, or in entities in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest, that were issued by GAZ Auto Plant (hereinafter, “Other Issuer Holdings”), to a non-U.S. person; or facilitate the transfer of Other Issuer Holdings by a non-U.S. person to another non-U.S. person, are authorized through 12:01 a.m. eastern daylight time, May 25, 2022. The transactions and activities authorized include facilitating, clearing, and settling transactions to divest to a non-U.S. person debt, equity, or other holdings in GAZ Group, or Other Issuer Holdings as described in paragraph (b), including on behalf of U.S. persons. https://home.treasury.gov/system/files/126/ukraine_gl13r.pdf
General License 15L: Authorizes all transactions and activities prohibited by the Ukraine Related Sanctions Regulations, 31 CFR part 589 (URSR), that are ordinarily incident and necessary to the wind-down of transactions involving GAZ Group, or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest, are authorized through 12:01 a.m. eastern daylight time, May 25, 2022.
https://home.treasury.gov/system/files/126/ukraine_gl15l.pdf
See the following link for Frequently Asked Questions related to General Licenses 13R and 15L: https://home.treasury.gov/policy-issues/financial-sanctions/faqs/updated/2022-04-25
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April 29, 2022: OFAC is amending and reissuing, in their entirety, the Ukraine-Related Sanctions Regulations, 31 C.F.R. part 589, and renaming the regulations the Ukraine-/Russia-Related Sanctions Regulations. This administrative action replaces the regulations that were published in abbreviated form on May 8, 2014 with a more comprehensive set of regulations that includes additional interpretive and definitional guidance, general licenses, and other regulatory provisions that will provide further guidance to the public. OFAC is also revising several FAQs for the Ukraine-/Russia-Related Sanctions Regulations.
https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220429
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Department of The Treasury
April 5, 2022: 87 Fed. Reg. 19737: In accordance with section 999(a)(3) of the Internal Revenue Code of 1986, the Department of the Treasury is publishing a current list of countries that require or may require participation in, or cooperation with, an international boycott (within the meaning of section 999(b)(3) of the Internal Revenue Code of 1986). The countries are:
- Iraq;
- Kuwait;
- Lebanon;
- Libya;
- Qatar;
- Saudi Arabia;
- Syria; and
- Yeman
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Fines and Penalties
April 1, 2022: OFAC settles with S&P Global, Inc. for $78,750 related to apparent violations of the Ukraine-Related Sanctions Regulations in 2016 and 2017. The apparent violations occurred when S&P Global and a company it acquired reissued and redated multiple invoices to continue to extend credit to JSC Rosneft (“Rosneft”), a state-owned Russian oil company, in violation of the debt and equity restrictions set forth under Executive Order (E.O.) 13662. After reissuing and re-dating four invoices to extend the original payment dates, S&P Global ultimately accepted past-due payments totaling $82,500 from Rosneft. The settlement amount reflects OFAC’s determination that S&P Global’s apparent violations were non-egregious and not voluntarily self-disclosed. https://home.treasury.gov/system/files/126/20220401_spglobal.pdf
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April 1, 2022: Former GE Power Engineer, Xiaoqing Zheng, of New York was convicted of conspiracy to commit economic espionage with individuals in China to steal GE Power & Water’s (“GE”) Trade Secrets Knowing or Intending to Benefit the Government of China. A federal jury convicted Zheng of conspiracy to commit economic espionage following a four-week jury trial. According to court documents and evidence presented at trial, Zheng, 59, of Niskayuna, NY was employed at GE Power & Water in Schenectady, New York, as an engineer specializing in sealing technology. He worked at GE from 2008 until the summer of 2018. The trial evidence demonstrated that Zheng and others in China conspired to steal GE’s trade secrets surrounding GE’s steam and gas turbine technologies, knowing or intending to benefit the People’s Republic of China and one or more foreign instrumentalities, including China-based companies that research, develop, and manufacture parts for turbines. https://www.justice.gov/opa/pr/former-ge-power-engineer-convicted-conspiracy-commit-economic-espionage
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April 4, 2022: The U.S. Department of Commerce's Bureau of Industry and Security (BIS) has issued the following five new Orders Denying Export Privileges:
- April 4, 2022: 87 Fed. Reg. 87 Fed. Reg. 19475: On March 10, 2020, in the U.S. District Court for the Southern District of Texas, Andrew Estrada (“Mr. Estrada”) was convicted of violating 18 U.S.C. 554(a). Specifically, Estrada was convicted of fraudulently and knowingly exporting and sending or attempting to export or send from the United States to Mexico, approximately 500 rounds of .38 Super caliber ammunition and two 7.62 x 39 mm drum magazines, in violation of 18 U.S.C. 554. As a result of his conviction, on March 10, 2020, the Court sentenced Mr. Estrada to 30 months in prison, three years of supervised release, and a $100 court assessment. Based on his conviction, BIS denied Mr. Estrada’s export privileges for seven (7) years from the date of his conviction.
- April 4, 2022: 87 Fed. Reg. 19477: On October 3, 2019, in the U.S. District Court for the Southern District of Texas, Guadalupe Horacio Garza-Cavazos (“Mr. Garza-Cavazos”) was convicted of violating 18 U.S.C. 554(a). Specifically, Mr. Garza-Cavazos was convicted of fraudulently and knowingly exporting and sending or attempting to export and send from the United States to Mexico, (1) SIG Sauer .380 Auto, (1) Beretta .22 LR, (1) Glock 17 9mm, (1) Glock 19 9mm, (1) Smith and Wesson 9mm, (1) SIG Sauer 9mm, (2) 20 round boxes of .308 caliber ammunition, (1) 20 round box of .30-30 caliber ammunition, and 12 pistol magazines, in violation of 18 U.S.C. 554. As a result of his conviction, the Court sentenced Mr. Garza-Cavazos to 46 months in prison and a $100 assessment. Based on his conviction, BIS denied Mr. Garza-Cavazos’ export privileges for ten (10) years from the date of his conviction. https://www.federalregister.gov/documents/2022/04/04/2022-07046/in-the-matter-of-guadalupe-horacio-garza-cavazos-inmate-number-87312-479-fci-butner-low-federal
- April 4, 2022: 87 Fed. Reg. 19478: On June 11, 2019, in the U.S. District Court for the Western District of Washington, Hicham Diab (“Mr. Diab”) was convicted of violating 18 U.S.C. 371. Specifically, Diab was convicted of knowingly and intentionally conspiring to willfully export firearms, defense articles designated on the United States Munitions List, from the United States to Lebanon, without having obtained from the United States Department of State a license or written approval for the export of these defense articles, in violation of 18 U.S.C. 371. As a result of his conviction, the Court sentenced Mr. Diab to 18 months imprisonment and a $200 assessment. Based on his conviction, BIS denied Mr. Diab’s export privileges for ten (10) years from the date of his conviction.
- April 4, 2022: 87 Fed. Reg. 19479: On June 11, 2019, in the U.S. District Court for the Western District of Washington, Nafez El Mir (“Mr. El Mir”) was convicted of violating 18 U.S.C. 371. Specifically, Mr. El Mir was convicted of knowingly and intentionally conspiring to willfully export firearms, defense articles designated on the United States Munitions List, from the United States to Lebanon, without having obtained from the United States Department of State a license or written approval for the export of these defense articles, in violation of 18 U.S.C. 371. As a result of his conviction, the Court sentenced Mr. El Mir to 18 months imprisonment and a $200 assessment. Based on his conviction, BIS denied Mr. El Mir’s export privileges for ten (10) years from the date of his conviction.
- April 4, 2022: 87 Fed. Reg. 19476: On May 23, 2019, in the U.S. District Court for the Southern District of Texas, Sergio Eduardo Perez-Barragan (“Mr. Perez-Barragan”) was convicted of violating 18 U.S.C. 554(a). Specifically, Perez-Barragan was convicted of fraudulently and knowingly exporting and sending from the United States or attempting to export and sending from the United States, one thousand (1,000) rounds of 9mm ammunition, three hundred and fifty (350) rounds of .380 caliber ammunition, two hundred (200) rounds of .243 caliber ammunition, and twenty (20) rounds of .270 caliber ammunition, in violation of 18 U.S.C. 554. Mr. Perez-Barragan was sentenced to 10 months in prison and a $100 assessment. Based on his conviction, BIS denied Mr. Perez-Barragan’s export privileges for seven (7) years from the date of his conviction.
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April 6, 2022: Konstantin Malofeyev (Mr. Malofeyev), 47, of Russia was charged with violating U.S. sanctions arising from the 2014 Russian undermining of democratic processes and institutions in Ukraine. According to the indictment, which was unsealed in the Southern District of New York, Mr. Malofeyev, was charged with conspiracy to violate U.S. sanctions and violations of U.S. sanctions in connection with his hiring of an American citizen, Jack Hanick (Mr. Hanick), to work for him in operating television networks in Russia and Greece and attempting to acquire a television network in Bulgaria. As alleged, Mr. Malofeyev also conspired with Mr. Hanick and others to illegally transfer a $10 million investment that Mr. Malofeyev made in a U.S. bank to a business associate in Greece, in violation of the sanctions blocking Mr. Malofeyev’s assets from being transferred. Along with the indictment, the United States issued a seizure warrant for Mr. Malofeyev’s U.S. investment. Mr. Malofeyev remains at large and is believed to be in Russia.
https://www.justice.gov/opa/pr/russian-oligarch-charged-violating-us-sanctions
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April 7, 2022: A Chinese national, Xiang Haitao (Xiang), 44, formerly residing in Chesterfield, Missouri, was sentenced to 29 months in prison followed by three years of supervised release and a $150,000 fine for conspiring to commit economic espionage. Xiang pleaded guilty to the charge in January 2022. According to court documents, Xiang conspired to steal a trade secret from The Climate Corporation, a subsidiary of Monsanto, an internationally based company doing business in St. Louis, Missouri, for the purpose of benefitting a foreign government, namely the People’s Republic of China (PRC).
https://www.justice.gov/opa/pr/chinese-national-sentenced-economic-espionage-conspiracy
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April 7, 2022: A former University of Kansas (KU) professor, Feng Tao, aka Franklin Tao (Tao), 50, was today convicted by a federal jury on three counts of wire fraud and one count of false statements after he deliberately concealed that he was also employed by a government-affiliated university in the People’s Republic of China (PRC), while working on U.S. government-funded research at KU. Tao of Lawrence, Kansas, worked as a full-time professor at KU. According to court documents and evidence presented at trial, in 2018, Tao accepted a position with Fuzhou University in China that designated him as a Changjiang Scholar Distinguished Professor. The position’s guidelines required him to be a full-time employee of Fuzhou University.
The Kansas Board of Regents (KBOR) required faculty to file annual reports to notify of any outside employment that did or could impact duties as a conflict of interest. Tao didn’t seek permission from KU before entering the agreement with Fuzhou University, didn’t notify KU about the employment, and lied to conceal the employment. In December 2018, the defendant moved to China to work full-time at Fuzhou University, while falsely telling KU administrators that he was in Europe. https://www.justice.gov/opa/pr/jury-convicts-university-kansas-researcher-hiding-ties-chinese-government
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April 8, 2022: A former Managing Director of The Goldman Sachs Group Inc. (Goldman Sachs), Ng Chong Hwa, aka Roger Ng (“Roger Ng”) of Malaysia was convicted by a federal jury in the Eastern District of New York for conspiring to commit bribery, to circumvent internal accounting controls, and to commit money laundering in connection with a multibillion-dollar scheme involving Malaysia’s state-owned investment and development fund, 1Malaysia Development Berhad (1MDB). Following an eight-week trial, Roger Ng was found guilty of conspiring to violate the Foreign Corrupt Practices Act (FCPA) by paying bribes to a dozen foreign officials in Malaysia and the United Arab Emirates, conspiring to violate the FCPA by circumventing the internal accounting controls of Goldman Sachs, and conspiring to launder billions of dollars related to the scheme.
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April 12, 2022: A Texas man and woman, Xiaojian Tao, 63 (Tao), and Yu Lang, aka Laura Lang, 63 (Lang) were arrested in Helotes on criminal charges related to the husband’s involvement in alleged export violations, and both of their alleged involvement in a scheme to defraud a research and development company (R&D Company) that provided services to industrial and government clients in the United States and abroad.
Tao is charged with one count of illegal export of defense articles; one count of unlawful export of commerce-controlled goods; and one count of making a false statement with regards to the Export Control Reform Act (ECRA). Tao allegedly exported items to China without having obtained a required export license from either the Department of State or the Department of Commerce. Tao and Lang are both charged with one count of conspiracy to commit wire fraud and nine counts of wire fraud. According to court documents, from 1997 to the present, Tao and Lang owned and operated Tyletech, aka Tylex Tech LLC, and Tyle Tech, a company that provides engineering consulting services. From 1994 to March 2020 Tao worked for the R&D Company that directly competed with Tyletech. Although Tao certified that each year he would notify the R&D Company of any conflicts of interest and follow Standards of Conduct, Tao and Lang hid Tao’s role in Tyletech, instead funneling business from the R&D Company to Tyletech. Further, from 2016 to 2020, Tao and Lang allegedly filed false income tax returns and are both charged with one count of conspiracy to defraud the United States and five counts of filing false tax returns. Tao also is charged with one count of making a false statement and Lang is charged with two counts of making a false statement.
If convicted, Tao faces a maximum of 20 years in prison on each of the export counts and the false ECRA statement. Tao and Lang face a maximum of 20 years in prison on each of the wire fraud counts; five years in prison on each of the false statement counts and the defrauding the U.S. count, and three years in prison on each of the false tax return counts.
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April 12, 2022: Virgil Griffith, 39 (Griffith) a U.S. citizen who conspired to provide services to the Democratic People’s Republic of Korea (DPRK or North Korea), including technical advice on using cryptocurrency and blockchain technology to evade sanctions, was sentenced to 63 months in prison after pleading guilty to conspiracy to violate the International Emergency Economic Powers Act (IEEPA).
According to court documents, Griffith began formulating plans as early as 2018 to provide services to individuals in the DPRK by developing and funding cryptocurrency infrastructure there, including to mine cryptocurrency. Griffith knew that the DPRK could use these services to evade and avoid U.S. sanctions, and to fund its nuclear weapons program and other illicit activities. https://www.justice.gov/opa/pr/us-citizen-who-conspired-assist-north-korea-evading-sanctions-sentenced-over-five-years-and
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April 12, 2022: A federal grand jury in the Middle District of Florida returned an indictment charging Lawrence O’Brien, Bruce LaRoche, and Thomas Dailey of Florida with conspiring to rig bids for customized promotional products to the U.S. Army and charging two of them with conspiring to defraud the United States. Two of the men were arrested early this morning, and all three appeared in court for initial appearances this afternoon. According to court documents, Lawrence O’Brien, Bruce LaRoche and Thomas Dailey conspired to eliminate competition among their companies and secure sales for a pre-arranged winner. To carry out this scheme, they exchanged their company’s bid templates and submitted bids to military customers on each other’s behalf.
https://www.justice.gov/opa/pr/three-florida-men-indicted-rigging-bids-and-defrauding-us-military
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April 20, 2022: Andrew Scott, Pierson, 46 (Pierson), of Jay, Oklahoma was sentenced to 12 years in prison for his role in a conspiracy that resulted in the trafficking of firearms to Mexican cartels. In May 2017, an Arkansas resident received a shipment of firearm components that had been sent to him for cerakoting, a process in which a polymer-ceramic coating is added to a firearm or its parts to improve durability. The parts appeared to be 80% Colt lower receivers, and the Arkansas resident recognized these firearm parts as counterfeit. He contacted law enforcement. The counterfeit receivers were traced to an organization in Laredo, Texas, which was transporting firearm parts to Pierson in Nuevo Laredo, Mexico. Pierson assembled the parts into functioning weapons for the Cartel Del Noreste (CDN) and Cartel Jalisco Nueva Generacion (CJNG). Pierson was arrested at the southern United States border on December 10, 2018. Pierson admitted to ordering and receiving firearm parts from the United States and manufacturing automatic weapons in Mexico for the CDN and CJNG cartels. Law enforcement later confirmed cartel firearm availability was impaired following Pierson’s arrest.
https://www.justice.gov/usao-edar/pr/oklahoma-man-sentenced-12-years-prison
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April 21, 2022: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a $141,442 settlement with Newmont Corporation (“Newmont”), a multinational mining firm headquartered in Denver, Colorado. Newmont has agreed to settle a potential civil liability for four apparent violations of the Cuban Assets Control Regulations (CACR), 31 C.F.R. part 515. Specifically, between approximately June 2016 to November 2017, Newmont Suriname, a wholly-owned subsidiary of Newmont that is a person subject to the jurisdiction of the United States under the CACR, purchased Cuban-origin explosives and explosive accessories from a third-party vendor involving four separate transactions. OFAC determined that Newmont voluntarily disclosed the apparent violations and that the apparent violations constitute a non-egregious case.
https://home.treasury.gov/system/files/126/20220421_newmont.pdf
Separately, OFAC announced a $45,908 settlement with Chisu International Corporation (“Chisu”), a company located in Parkland, Florida that is affiliated with a distributor of explosives and accessories for mining operations. Chisu has agreed to settle a potential civil liability for four apparent violations of the Cuban Assets Control Regulations (CACR), 31 C.F.R. part 515. Specifically, between June 2016 and November 2017, Chisu and its affiliates in Suriname and Panama on four occasions procured Cuban-origin explosives and related accessories originating from the Cuban entity Unión Latinoamericana de Explosivos (ULAEX) on behalf of a U.S. company for the U.S. company’s mining project in Suriname. OFAC determined that Chisu did not voluntarily disclose the apparent violations and that the apparent violations constitute a non-egregious case. https://home.treasury.gov/system/files/126/20220421_chisu.pdf
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April 25, 2022: The United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a settlement with Toll Holdings Limited (“Toll”), an international freight forwarding and logistics company headquartered in Melbourne, Australia. Toll agreed to remit $6,131,855 to settle its potential civil liability for 2,958 apparent violations of the Iranian Transactions and Sanctions Regulations, the North Korea Sanctions Regulations, and the Syrian Sanctions Regulations, the Weapons of Mass Destruction Proliferators Sanctions Regulations, and the Global Terrorism Sanctions Regulations. The apparent violations occurred when Toll originated or received payments through the U.S. financial system involving sanctioned jurisdictions and persons. These payments were in connection with the sea, air, and rail shipments conducted by Toll, its affiliates, or suppliers to, from, or through the Democratic People’s Republic of Korea, Iran, or Syria, or the property or interests in property of an entity on OFAC’s list of Specially Designated Nationals and Blocked Persons. The settlement amount reflects OFAC’s determination that Toll’s apparent violations were non-egregious and voluntarily self-disclosed. https://home.treasury.gov/system/files/126/20220425_toll.pdf
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April 25, 2022: ALEJANDRO CAO DE BENOS, a citizen of Spain, and CHRISTOPHER EMMS, a citizen of the United Kingdom, were indicted and charged with conspiring to violate United States sanctions on the Democratic People’s Republic of Korea (DPRK or North Korea” by working with U.S. citizen Virgil Griffith to illegally provide cryptocurrency and blockchain technology services to the DPRK. Both CAO DE BENOS and EMMS remain at large. Griffith previously pled guilty to conspiring to assist North Korea in evading sanctions in violation of the International Emergency Economic Powers Act (“IEEPA”) and was sentenced to 63 months in prison and a $100,000 fine. https://www.justice.gov/usao-sdny/pr/us-attorney-announces-charges-against-two-european-citizens-conspiring-us-citizen