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Last week's major developments in sanctions - Nov. 8th to Nov. 12th, 2021

Monday, November 8th

- This week started with two actions taken by OFAC and FinCEN. OFAC designated two individuals and five entities pursuant to the authority granted in E.O. 13694. (Here) Concurrently, FinCEN updated its Advisory on Ransomware and the Use of the Financial System to Facilitate Ransom Payments. (Department of Treasury's press release)

Tuesday, November 9th - The EU Council removed one individual from its sanctions list who was targeted under its Libya sanctions regime. (Here)

- OFAC published FAQ 934 which clarifies the scope of the already-existing authorizations within the Syrian sanctions program. (Here)

- OFAC published a Finding of Violation (less grave than civil monetary penalty yet important enough to share it publicly) issued to Mashreqbank. This was part of a broader settlement the bank entered with a number of regulators in the United States. Mashreqbank processed transactions in breach of the now-repealed Sudan sanctions program between 2005 and 2009. You may wonder how OFAC could go that far back in time. The response is that Mashreqbank entered into a retroactive statute of limitations waiver agreement which in turn was considered as one of the mitigating factors. Even though OFAC did not impose any monetary penalty, Mashreqbank agreed to pay $100 million to NYDFS. (Here)

- The UNSC committee in charge of Yemen sanctions added three individuals to the list of its targets. (Here)

Wednesday, November 10th

- France extended the designation period of 12 individuals and entities which were sanctioned pursuant to article L562-3 of the monetary and financial code of France. (Here)

- OFAC designated two military officials in Cambodia under the Global Magnitsky Act. (Here, press release) In addition, the Dept. of Treasury, Commerce, and State issued Cambodia Business Advisory on High-Risk Investments and Interactions. The Dept. of State also imposed visa bans against the two designated persons and their immediate family member pursuant to section 7031(c) of the Department of State, Foreign Operations, and Related Programs Appropriations Act, 2021. (Here)

Thursday, November 11th

- The EU Council in an administrative move extended the validity of restrictive measures in view of Turkey’s unauthorized drilling activities in the Eastern Mediterranean for another year. (Council's Decision, press release)

Friday, November 12th

- The committee in charge of UNSC sanctions in Yemen updated its Guidelines. (Here)

- OFAC designated two individuals and four entities pursuant to the new Ethiopian sanctions regime. Concurrently, OFAC issued a general license for winding down certain activities, published two new FAQs, and updated one FAQ. (Here, press release) OFAC also amended the information about several entries on the SDN list.

Recommendations of the week

- If you want to see how serious the U.S. government is about ransomware attacks, first see the rewards it offered for information leading to the identification or location of any individual holding a key leadership position in the Sodinokibi ransomware variant transnational organized crime group, and just few days after, the DOJ press release about an arrest and charges filed against individuals believed to be behind some of the recent attacks to the United States.

- In case you missed it FATF updated its Guidance for a Risk-Based Approach to Virtual Assets and Virtual Asset Service Providers a while ago. (Here)


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