OFAC sanction activity

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The Office of Foreign Assets Control last week announced its second round of Hamas-related sanctions after the terror group’s killings in Israel earlier this month, designating more Hamas-linked officials and financial networks. The agency sanctioned people helping Hamas evade sanctions, their companies and other entities with ties to the group.

Jenner & Block partner Rachel Alpert was tapped to serve as the chief counsel to the Treasury Department's Office of Foreign Assets Control, the firm announced on Oct. 24. Alpert has worked at Jenner & Block since 2021 and has fleshed out the firm's national security, sanctions and export controls practice, along with the human rights and global strategy practice. Her practice centered around export controls and sanctions proceedings under the International Traffic in Arms Regulations, Export Administration Regulations and OFAC regulations, among other things. Prior to working at Jenner & Block, Alpert worked as an attorney-adviser to the State Department and as counsel at Latham & Watkins.

The U.S. last week removed sanctions from the son of a convicted war criminal about six months after he, his sister and mother sued the Treasury Department for taking too long to adjudicate their delisting requests.

The Office of Foreign Assets Control last week sanctioned two people and four entities for being a part of Serb Republic President Milorad Dodik’s “patronage network” and supporting his “ongoing corruption,” including by allowing him to siphon public funds to enrich himself and his family. OFAC said Dodik uses his position in the Serb Republic, one of two entities making up Bosnia and Herzegovina, to “accumulate personal wealth through graft, bribery, and other forms of corruption.”

The Office of Foreign Assets Control this week sanctioned various Hamas members, operatives and financial facilitators in an effort to “root out” the terror group’s revenue sources in the West Bank, Gaza and throughout the region. OFAC said the designations build on the nearly 1,000 people and entities already sanctioned by the agency and who are connected to terrorism and terrorist financing by the Iranian regime and its “proxies.”

The U.S. this week sanctioned 11 people, eight entities and one vessel with ties to Iran’s ballistic missile and drone programs. The Treasury, Commerce and State departments, along with DOJ, also published a new advisory to alert global companies about Iran’s ballistic missile procurement activities.

The U.S. has little room to expand sanctions against Hamas, but it could look to track down and designate additional front companies the terror group uses to fund its activities, said Jason Prince, former chief counsel at the Office of Foreign Assets Control. Although OFAC has general licenses in place to authorize a broad range of humanitarian-related transactions involving Palestine, Hamas’ designation as a foreign terrorist organization could make some financial institutions less willing to approve those aid-related transactions, Prince said.

Farhad Nafeiy, a California-based telecommunications consultant, pleaded guilty this week to violating the International Emergency Economic Powers Act after he breached the scope of sanctions licenses from the Office of Foreign Assets Control.

The U.S. this week sanctioned a China-based network of companies and people involved in manufacturing and distributing “ton quantities” of fentanyl, methamphetamine and MDMA precursors. The designations also target two entities and one person based in Canada.