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Last week's major developments in sanctions - November 6th to November 10th, 2023

Monday, November 6

  • FinCEN and BIS issued a joint notice highlighting a new Suspicious Activity Report (SAR) key term, "Fin-2023-GLOBALEXPORT" for financial institutions to reference when reporting potential efforts by individuals or entities seeking to evade US export controls not related to Russia's invasion of Ukraine. ( The Notice, and BIS Press Release) This is an interesting development that goes in line with the increasing expectations from financial institutions regarding export controls.

  • OFAC announced a $206,213 settlement with daVinci Payments a prepaid reward card provider based in the United States, for apparent violations of sanctions on Crimea, Iran, Syria, and Cuba. Why? Similar to many enforcement actions against fintech companies, they did not screen the IP address they had and as a result, provided services to comprehensively sanctioned jurisdictions. (Here)

Tuesday, November 7

  • OFAC imposed blocking sanctions on 13 individuals and four Mexico-based entities for their involvement with Sinaloa Cartel. (Here, and the Department of the Treasury's press release)

  • BIS issued a Temporary Denial Order suspending the export privileges of seven persons and three companies. These ten parties are alleged to be a part of a sophisticated global procurement scheme that unlawfully sourced and purchased millions of dollars in dual-use electronics for end-users in Russia, including companies affiliated with the Russian military. (Temporary Denial Order, and Press Release)

  • In an AML-related development, FinCEN issued a final rule specifying the circumstances that Beneficial Ownership policies in which a reporting company may report an entity's FinCEN identifier in lieu of information about an individual beneficial owner. (Press Release, and the Rule)

Wednesday, November 8

  • OFSI imposed asset-freezing sanctions against 20 individuals and nine entities for supporting Russian oil, gold, and strategic centers. Among the recently designated persons were, Nord Gold and Highland Gold Mining, two of the largest producers of Russian gold, and Paloma Precious DMCC, a UAE-based network that allegedly has channeled $300 million in gold revenues to Russia. (OFSI Sanctions Notice, and Press Release)

  • The UK's National Crime Agency issued an alert to financial institutions and other members of the regulated sector warning that Russia is using gold as a means to undermine the impact of the UK sanctions regime. (Here)

Thursday, November 9

  • OSFI imposed blocking sanctions against nine individuals and six entities under its Russia sanctions regime for their role in the Kremlin-backed orchestration of disinformation and war propaganda, directly promoting Russia's war of aggression against Ukraine. (Here, and Press Release)

  • The European Union has renewed restrictive measures against Turkiye for unauthorized drilling in the Eastern Mediterranean to November 30, 2024. (Council Decision) As of this date, only two individuals are sanctioned under this regime.

Friday, November 10

  • OFSI amended General Licence INT/2022/1839676 to make clear that Paragraph 4.1 only permits the purchase of tickets from a DP or any Subsidiary for passenger rail or passenger air journeys originating in, or within, Russia. (Here)

  • The EU Official Journal published three sanctions-related decisions of the Council on Thursday:

    1. Council Decision 2023/2487 which amended the EU sanctions regime against the Central African Republic in line with the United Nations Security Council Resolution 2693 adopted on 27 July 2023;

    2. Council Decisions 2023/2499 and 2023/2503 which removed four and amended two entries under the EU sanctions regime against Libya.

Recommendation of the Week

  • Basel AML Index 2023 is out! Check it out here: Public Ranking - Basel AML Index

  • If you want to know more about the recent FinCEN Notice of Proposed Rule Making that identifies international convertible virtual currency mixing as a class of transactions of primary money laundering concern, and the industry's response to it, check out this alert.


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