Export Compliance Daily is providing readers with the top stories from last week in case you missed them. You can find any article by searching for the title or by clicking on the hyperlinked reference number.
OFAC sanction activity
The Office of Foreign Assets Control this month released new guidance to outline how people and companies should submit information, documents and “other materials” to the agency during a sanctions breach investigation, for voluntary disclosure, in response to an OFAC subpoena, and more. The guidance updates the agency’s “former data delivery standards,” OFAC said, and “provides technical and general guidance to persons submitting material to OFAC,” especially for submissions “that may entail voluminous documentation (e.g., more than 100 pages).” The document includes guidance for “organizing document productions,” includes “general conventions for submitting electronic documents,” and provides guidance on submitting data under and over 150 megabytes in total size.
The Office of Foreign Assets Control deleted two Russia-related entries from its Specially Designation Nationals List. The agency removed Marina Igorevna Tsareva, who was sanctioned in 2018 for helping to procure underwater equipment and diving systems for Russian government agencies, and Alexey Valeryevich Panferov, who OFAC had sanctioned in 2022 as part of a tranche of designations targeting Russia's defense industrial base. An agency spokesperson didn't immediately respond to a request for comment about why OFAC removed both from the SDN List.
Charlotte Baskin-Gerwitz, a former Office of Foreign Assets Control sanctions compliance officer, has joined J.P. Morgan as its vice president of global sanctions advisory, she announced July 1 on LinkedIn. Baskin-Gerwitz, who left OFAC in 2023, most recently worked as an associate in Morrison Foerster’s national security practice.
The Office of Foreign Assets Control on July 3 updated a range of Russia-related entries on its Specially Designated Nationals List and Sectoral Sanctions Identifications List to specify that they present secondary sanctions risks. The agency added language to those entries to clarify that they present a secondary sanctions risk under “Section 11 of Executive Order 14024,” a 2021 order that authorizes certain sanctions against Russia. The agency didn’t provide more information.
Export Compliance Daily is providing readers with the top stories from last week in case you missed them. You can find any article by searching for the title or by clicking on the hyperlinked reference number.
The Office of Foreign Assets Control this week sanctioned one person in Mexico and two in China for their ties to the Sinaloa Cartel, a Mexican drug trafficking group. The designations target Mexico-based Diego Acosta Ovalle, who helped the cartel hide and collect drug trafficking money, and China-based Tong Peiji and He Jiaxuan, members of a U.S.-based Chinese money laundering organization that has laundered illegal drug proceeds belonging to the Sinaloa Cartel.
The Office of Foreign Assets Control plans to issue guidance on a law signed by President Joe Biden in April that extended the statute of limitations on certain sanctions violations from five to 10 years (see 2404290071 and 2404240043), Baker McKenzie said in a client alert this week. The law firm recently hosted a talk with OFAC official Lawrence Scheinert who said the agency is “working through the relevant legal issues” and plans to issue guidance about how the “change will be implemented,” Baker McKenzie said.
The U.S. fined an Italian animation company $538,000 after it violated U.S. sanctions by outsourcing work to an animation studio owned by the North Korean government, the Office of Foreign Assets Control said in an enforcement release. The company, Mondo TV, illegally used U.S. banks to send money to the studio through wire transfers, OFAC said.
The Office of Foreign Assets Control this week sanctioned about 50 entities and people, including a “sprawling” shadow banking network, used by Iran’s military to access the international financial system. Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL) and the Islamic Revolutionary Guard Corps have used the network to process billions of dollars since 2020, OFAC said, and use various exchange houses and foreign “cover companies” to “disguise the revenue they generate abroad,” which they then use to buy and develop advanced weapons systems.