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Last week's major developments in sanctions - October 31st to November 4th, 2022

Monday, October 31

  • OFAC published a new FAQ to provide clarity on the applicability of the price cap to the oil originated in Russia that has been loaded on to a vessel before December 5 (the day the price cap will be effective). (Here)

Tuesday, November 1

  • The United States imposed blocking sanctions on eight individuals who allegedly sold weapons to or were active al-Shabaab (an ISIS affiliated group) members. All the designations were made under the United States Global Counter Terrorism sanctions program and have the risk of "secondary" sanctions attached to them. (Here, the Department of the Treasury's press release, the Department of State's press release)

  • The Financial Crimes Enforcement Network ("FinCEN") issued a trend analysis of ransomware-related SARs filled with it from July to December of 2021. The three finding of the analysis are (i) substantial increase of ransomware-related incidents compared to the previous year; (ii) ransomware-related BSA filings in 2021 approached $1.2 billion; and (iii) most of the ransomware-related incidents reported to FinCEN during the second half of 2021 pertained to Russia-related ransomware variants. (Here) As a reminder, it is vital to assess the risk of sanctions violations related to any ransomware payment.

Wednesday, November 2

  • OFSI added four individuals to its list of sanctions targets. The four individuals are all designated under the UK's Russia sanctions regime and are subject to blocking sanctions. (Here)

Thursday, November 3

Friday, November 4

  • OFSI issued a major general license INT/2022/2349952 authorizing certain transactions related to agricultural commodities including the provision of insurance and other services. (Here)

  • Both OFAC and the United States Department of State took action against Haitian officials for their roles in trading illicit drugs. Specifically, OFAC imposed blocking sanctions on Joseph Lambert and Youri Latortue while the Department of State imposed travel bans on Joseph Lambert, Lambert’s spouse, Jesula Lambert Domond, and their immediate family members. (Here, the Department of the Treasury's press release, the Department of State's press release)

Recommendation of the week

  • This week I would like to recommend a WSJ article about why removing sanctions related to Tornado cash is not easy. Check it out here!

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