In the past week, both the Office of Foreign Assets Control (“OFAC”) in the US Treasury Department and the Financial Crimes Enforcement Network (“FinCEN”) took steps related to Hamas, which they indicated were linked to the recent Hamas attacks on Israel. New OFAC Sanctions On October 18, 2023, OFAC added a number of parties determined to be connected to Hamas to its Specially Designated Nationals and Blocked Persons List (“SDN”). As described in the…
On September 8, 2023, the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) published a Financial Trend Analysis (“FTA”) highlighting trends related to suspected evasion of Russia-related export controls observed in reports required to be filed by financial institutions with FinCEN under the Bank Secrecy Act (“BSA”), such as through suspicious activity reports. The FTA highlights certain evasion red flags useful for purposes of companies’ own compliance efforts, while also serving as a…
In two separate rounds of sanctions designations in the past week, the United States added more parties to the Specially Designated Nationals List (“SDN List”) maintained by the Office of Foreign Assets Control (“OFAC”) in the US Treasury Department. These designations are noteworthy given their scope and, in the case of the Iran-related designations, the fact that they included parties in China, Russia, and Türkiye. Not only does this increase the risk of encountering sanctioned…
On August 23, 2023, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued the first Determination Pursuant to Section 1(a)(i) of Executive Order (“EO”) 14014 (the “Determination”), which extends the application of section 1(a)(i) of EO 14014 to the jet fuel sector of the Burmese economy. On the same day, OFAC also published two related Frequently Asked Questions (“FAQs”): FAQ 1132 and FAQ 1133. Our blog post on the issuance of EO 14014…