The Treasury’s Office of Foreign Assets Control sanctioned seven individuals and three entities that move money in Europe, Africa and the Middle East, because they were supporting terrorism and serving as “financial facilitators” for ISIS, according to an April 15 press release from OFAC. Six of the individuals and one of the entities are part of the Rawi Network, which, the U.S. says, helped ISIS government officials launder the money from selling Iraqi oil when they controlled territory there, as well as distributing donations to ISIS through an informal money transfer system known as hawala.

The Treasury’s Office of Foreign Assets Control sanctioned four companies and nine ships associated with transporting oil to and from Venezuela in another effort to isolate the Nicolas Maduro regime, OFAC said in an April 12 notice. OFAC said the companies used the oil tankers to deliver oil from Venezuela to Cuba between January and March. Six of the ships were linked to PB Tankers S.P.A., based in Italy. One each was linked to Liberia-based companies Jennifer Navigation Limited, Large Range Limited and Lima Shipping Corporation. The notice includes the maritime identification numbers and names of the ships owned by PB Tankers: Silver Point, Alba Marina, Gold Point, Ice Point, Indian Point and Iron Point. In a statement, Treasury Secretary Steven Mnuchin said OFAC will continue to target companies that transport Venezuelan oil to Cuba, as they “are profiting while the Maduro regime pillages natural resources.”

The Treasury’s Office of Foreign Assets Control sanctioned a Lebanese national and two of his companies for money laundering on behalf of drug kingpins and Hizballah, OFAC said in an April 11 notice. Kassem Chams and his two businesses, Chams Exchange Company Sal and Chams Money Laundering Organization, are being designated as Specially Designated Narcotics Traffickers and sanctioned under the Foreign Narcotics Kingpin Designation Act.

The departments of State and the Treasury, along with the U.S. attorney general, announced sanctions against an Iranian man for contributing to “proliferation of weapons of mass destruction or their means of delivery,” according to a notice to be published in the April 10 Federal Register. State said Reza Ebrahimi is being designated under a 2005 Executive Order titled “Blocking Property of Weapons of Mass Destruction Proliferators and Their Supporters.” The designation took effect March 22, 2019.

The U.S. designated the Islamic Revolutionary Guard Corps as a Foreign Terrorist Organization, marking the first time the U.S. has labeled a government an FTO, according to an April 8 White House notice. The designation is designed to increase financial pressure on Iran and isolate it from military resources, which the notice said are used for “terrorist activities.” The designation will take effect April 15, according to a statement made at a State Department briefing April 8 by Assistant Secretary of State for Counterterrorism Nathan Sales: "With the announcement today, which will take effect a week from now, the legal status of the IRGC will change from an organization to a designated foreign terrorist organization."

The Treasury's Office of Foreign Assets Control sanctioned two oil companies operating in the Venezuelan oil sector and identified 34 ships associated with Petróleos de Venezuela (PdVSA), according to an April 5 press release. OFAC identified the two shipping companies as Liberia-based Ballito Bay Shipping Incorporated and Greece-based ProPer In Management Incorporated, and said one or both transported oil from Venezuela to Cuba during February and March using an oil tanker called Despina Andrianna. OFAC also named the 34 ships that are “blocked property” of PdVSA, a Venezuela state-run oil company sanctioned by the U.S.

The Trump administration is considering increasing sanctions pressure on Venezuela by imposing sanctions on companies from third countries that do business with President Nicolas Maduro and the Venezuelan regime, according to a March 29 report by Reuters. The potential move was announced by John Bolton, White House national security adviser, who told Reuters the administration is moving in the “direction” of secondary sanctions.

The Treasury's Office of Foreign Assets Control issued several counter-terrorism, non-proliferation and Iran-related designations, OFAC said in a March 26 notice. The designations include nine people and 14 entities linked to Iran, the United Arab Emirates and Turkey, according to the notice. OFAC also updated two Iran-related listings on the Specially Designated Nationals List.

The Treasury's Office of Foreign Assets Control updated its Specially Designated Nationals List with several Iran-related designations and non-proliferation designations, OFAC said in a March 22 notice. The additions include 14 individuals and 17 entities, according to the notice, all of which have connections to Iran.

The Treasury’s Office of Foreign Assets Control’s recent action of sanctioning Evrofinance -- a Russian bank the U.S. suspects of working with the Venezuelan government -- was a two-part warning to Venezuela, the Kremlin and others, trade lawyer and former OFAC senior sanctions policy adviser Michael Dobson said in an interview. The U.S. will not hesitate to tighten restrictions on Venezuela, Dobson said, and it does not feel constrained to sanction “outside actors” assisting the Nicolas Maduro regime. The sanction (see 1903110014), announced in a March 11 OFAC notice, will be published in the March 22 Federal Register. Dobson, now a lawyer at Morrison Foerster, said he suspects Evrofinance of being a “very narrow vehicle” set up by Russia and Venezuela to facilitate trade and to “release some of the pressure from the Maduro regime's decreasing access to U.S. dollars.” The action will likely not become a trend for Venezuela, Dobson said, but a stand-alone action wherein the U.S. was able to enforce evasions of sanctions. “I think it’s just a warning,” Dobson said, adding that as long as U.S. companies aren’t doing business with Venezuela or Evrofinance, “I don't think this is going to have significant ripple effects.”