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Last week's major developments in sanctions - June 3rd, 2024, to June 7th, 2024

Monday, June 3
  • There was no major development on this day.

Tuesday, June 4
  • There was no major development on this day.

Wednesday, June 5
  • OFAC amended Syrian Sanctions Regulations. These amendments incorporated an executive order, statutes, and general licenses. (Here) Key changes include:

    • Incorporation of restrictions in an executive order and several statutes related to the Syria sanctions program. Specifically, OFAC added relevant parts of Caesar Syria Civilian Protection Act of 2019, the Syria Human Rights Accountability Act of 2012, and the Iran Threat Reduction and Syria Human Rights Act of 2012, as well as relevant provisions of the Countering America’s Adversaries Through Sanctions Act and Executive Order 13608.

    • Incorporation of web GL 22 related to economic sectors in certain areas of Syria.

    • Amendment of the NGO general license to clarify covered persons, add authorized activities, and allow U.S. financial institutions to rely on the originator's statements for fund transfers under the NGO GL, provided that the financial institution does not know or have reason to know that the funds transfer is not in compliance with the NGO general license.

    • Addition of new international organizations whose official business is authorized by the NGO general license to include the International Committee of the Red Cross and the International Federation of Red Cross and Red Crescent Societies; and The Global Fund to Fight AIDS, Tuberculosis, and Malaria, and Gavi, the Vaccine Alliance.

    • Expansion of authorization for internet-based communications by updating the list of examples of communications technologies that are incident to, or enable services incident to, communications over the internet; authorizing the provision of services incident to the export or reexport of certain communications software or hardware; and authorizing the exportation and re-exportation to Syria of non-commercial-grade internet connectivity services.

Thursday, June 6
  • OFAC imposed blocking sanctions on one individual and nine entities under various sanctions programs (here):

Friday, June 7
  • France imposed asset-freezing sanctions against five individuals and three entities under its autonomous counter-terrorism sanctions regime. (Here)

  • OFAC removed 30 entries from its SDN lists. All those entries were designated under the Russia program and most of them were in Switzerland. (Here)

Recommendations for the week
  • Last week, the U.S. Department of the Treasury released the 2024 Non-fungible Token (NFT) Illicit Finance Risk Assessment. This assessment examines how vulnerabilities related to NFTs and NFT platforms could be exploited by illicit actors for purposes such as money laundering, terrorist financing, and proliferation financing. You can find it here.

  • FinCEN published its FY 2023 Year in Review: Financial Crimes Enforcement Network (FinCEN) Bank Secrecy Act (BSA) Data Fiscal Year 2022


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