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Last week's major developments in sanctions - January 8th, 2024, to January 12th, 2024

Monday, January 8
  • A California resident and Russian national pleaded guilty to attempting to provide material support to Hayat Tahrir al-Sham, a designated foreign terrorist organization. (Here)

Tuesday, January 9
  • FinCEN issued a Financial Trend Analysis on information linked to identity-related suspicious activity in Bank Secrecy Act (BSA) reports filed in 2021. (Here, Financial Trend Analysis)

  • France imposed asset-freezing sanctions on one individual under France’s autonomous counter-terrorism sanctions program. (Here)

Wednesday, January 10
  • The Export Control Joint Unit (ECJU) released a notice to exporters on best practices for license applications. (Here)

Thursday, January 11
  • OFAC imposed asset-freezing sanctions on one individual, two entities, and three aircraft. (Here)

  • Potential sanctions violations penalties just got more expensive! OFAC amended its regulations to implement the Federal Civil Penalties Inflation Adjustment Act. This amendment adjusts for inflation, the maximum amount of civil monetary penalties that may be assessed under relevant OFAC regulations (Here, Inflation Adjustment of Civil Monetary Penalties Amendment)

  • The Department of State imposed asset-freezing sanctions against three Russian entities and one individual, and identified four aircraft as blocked property, for their involvement in the transfer and testing of Democratic People’s Republic of Korea ballistic missiles for Russia’s use against Ukraine. (Here, Fact-Sheet)

  • France imposed asset-freezing sanctions on two entities under France’s autonomous counter-terrorism sanctions regime. (Here)

Friday, January 12
  • OFAC imposed asset-freezing sanctions on two companies and identified four vessels as blocked property for their involvement in shipping Iranian commodities on behalf of IRGC-QF-backed Houthi financial facilitator, Sa’id al-Jamal. OFAC removed asset-freezing sanctions on one aircraft. (Here, Department of Treasury press release, Department of State press release)

  • FinCEN has updated its Beneficial Ownership Information Frequently Asked Questions. (Here)

  • The Bureau of Industry and Security (BIS), under the Department of Commerce, is seeking OMB approval for an information collection extension regarding import, end-user, delivery verification certificates, and firearms entry clearance requirements. (Here)

  • The EU Council established a dedicated framework for restrictive measures in support of democracy and a peaceful and orderly transfer of power in Guatemala, and to hold accountable those obstructing a democratic transition following the 2023 general elections. Any targeted restrictive measures shall consist of a travel restriction for individuals and an asset freeze for individuals and entities. Please note that no one is sanctioned under this program yet. (Decision, EU Council Press release)


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