The Treasury’s Office of Foreign Assets Control sanctioned one entity, three people and five ships for evading U.S. sanctions and delivering jet fuel to Russian forces in Syria, Treasury said Sept. 26.

The Treasury’s Financial Crimes Enforcement Network issued a guidance document and an advisory on regulations and illegal activity in convertible virtual currency fields, FinCEN said in a May 9 press release. The advisory aims to help companies identify and report “suspicious activity” related to the exploitation of CVCs for money laundering and sanctions evasions, FinCEN said, including recognizing “red flags.” In the advisory, FinCEN urges companies to screen their customers and business partners against the Office of Foreign Assets Control’s Specially Designated Nationals List and take “appropriate steps” to stop people in sanctioned countries from “trading in digital currency.” Businesses dealing in virtual currencies should have procedures in place to block IP addresses associated with sanctioned entities, disable accounts of holders from sanctioned countries, “install a dedicated Compliance Officer” to oversee compliance with all OFAC sanctions programs and ensure OFAC compliance training for all pertinent personnel, the advisory said.

The Treasury’s Office of Foreign Assets Control sanctioned two people and three entities for “acting as conduits for sanctions evasion schemes” for Hizballah, OFAC said in an April 24 press release. Belgium-based Wael Bazzi and Lebanon-based Hassan Tabaja were sanctioned for acting on behalf of family members who are Hizballah financers, OFAC said, and Belgium-based Voltra Transcor Energy BVBA, Belgium-based OFFISCOOP NV and United Kingdom-based BSQRD Limited were sanctioned for being owned by Bazzi. OFAC also updated an existing item on its Specially Designated Nationals List, adding Energy Engineers Procurement and Construction as an alias for Global Trading Group NV, which is owned by Wael Bazzi’s father, Mohammad Bazzi.

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.”