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Last week's major developments in sanctions - October 10th to October 14th, 2022

Monday, October 10

  • OFSI added seven individuals and one entity, the Morality Policy of Iran, to the list of sanctions targets in the UK under the country's sanctions regime against Iran for human rights violations. (Here, press release)

Tuesday, October 11

  • OFAC and FinCEN concurrently announced enforcement actions against Bittrex, Inc., a U.S.-based crypto exchange and wallet provider.

    1. OFAC's Action: Bittrex paid approximately USD 25 million to settle several apparent violations of U.S. sanctions. Bittrex has IP addresses and physical addresses of its users indicated that they were located in comprehensively sanctioned countries or regions. Main takeaway: if you have the data, you need to use it for sanctions compliance!

    2. FinCEN's Action: Bittrex failed to implement a functioning AML compliance program and it failed to file Suspicious Activity Reports ("SARs") with FinCEN. Main takeaway: set up a compliance function as you grow in line with your risk profile.

  • An associate of Oleg Deripaska who helped him to evade U.S. sanctions who was previously charged, was arrested and will go in front of court in the UK to battle his extradition to the United States. (Here)

  • The United States Department of State imposed visa bans (a type of sanctions) on current or former Taliban members, members of non-state security groups, and other individuals believed to be responsible for, or complicit in, repressing women and girls in Afghanistan through restrictive policies and violence pursuant to Section 212(a)(3)(C) of the Immigration and Nationality Act. (Here)

Wednesday, October 12

  • The United States Department of State provided further assurance to the U.S. technology companies that the United States government supports the free flow of information to sanctioned countries including Iran. (Here)

Thursday, October 13

  • The EU Council in two administrative actions extended its Nicaragua sanctions regime and its chemical weapons sanctions regime for another year. (Here for Nicaragua, and here for chemical weapons)

Friday, September 14

  • Departments of State, Commerce, and Treasury issued a joint alert to highlight the impact of sanctions on Russia’s Military-Industrial Complex. (Here) Concurrently, OFAC published a new FAQ warning the non-U.S. person about the risk of being designated if they provide ammunition or other military goods to Russia or for supporting Russia’s military-industrial complex.

Recommendation of the week

  • This week I would like to recommend the great work of Juan Zarate about how North Korea is using cryptocurrencies to further its objectives. The paper called "The North Korean Crypto Threat" was published by the Crypto Council for Innovation.


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