The EU is considering entities to be subject to sanctions if they are owned 50% or more by another sanctioned entity or party, a move that aligns the bloc with the U.S. Office of Foreign Assets Control’s 50% rule. The announcement is a change from the EU’s previous position on the ownership test threshold, which had previously extended asset freezes to entities only if they were owned more than 50% by a sanctioned party, a law firm said this week.
OFAC sanction activity
The Office of Foreign Assets Control plans to extend its sanctions-related recordkeeping requirements to match a similar expansion of the U.S. statute of limitations for sanctions violations that was signed into law earlier this year (see 2404290071).
The U.S. Supreme Court's recent decision upending the Chevron principle of deferring to federal agencies' interpretations of ambiguous statutes requires a more demanding review of the Office of Foreign Assets Control's use of the Global Magnitsky Act and International Emergency Economic Powers Act, sanctioned Mir Rahman Rahmani and his son, Hafi Ajmal Rahmani, argued (Mir Rahman Rahmani v. Janet Yellen, D.D.C. # 24-00285).
Samuel Cutler, a former sanctions and export control lawyer with Miller & Chevalier, joined the Office of Foreign Assets Control as an enforcement officer, he announced last week on LinkedIn. Cutler said he began the new role this month.
The Office of Foreign Assets Control last week sanctioned two members of the Russian “hacktivist group” Cyber Army of Russia Reborn, Yuliya Vladimirovna Pankratova and Denis Olegovich Degtyarenko, for cyberattacks against U.S. critical infrastructure. OFAC said Pankratova is the group's leader and Degtyarenko is its primary hacker, and they have helped the group conduct cyberattacks against Ukraine and governments and companies supporting Ukraine.
The Office of Foreign Assets Control is updating its license application process and portal to alert applicants where their application is in the agency’s “processing timeline,” OFAC said July 18. After submitting an application, the applicant will now start receiving one of 10 “case statuses” as their application is reviewed:
The Office of Foreign Assets Control this week sanctioned more people and vessels across Asia and the Middle East for their roles in aiding the Yemen-based Houthis through illegal shipping and financing networks. OFAC said the designations specifically target people with ties to Houthi financier Sa’id al-Jamal see (see 2406170026, 2312280012, 2401120015 and 2403260016).
The Office of Foreign Assets Control this week sanctioned three accountants and four companies linked to a timeshare fraud led by the Mexico-based Cartel de Jalisco Nueva Generacion. OFAC, the Financial Crimes Enforcement Network and the FBI also issued a joint alert urging financial institutions to submit suspicious activity reports to FinCEN about transactions that may be tied to timeshare fraud in Mexico, along with several red flags to monitor.
The Office of Foreign Assets Control this week updated an entry on its Specially Designated Nationals List for Aviad Shlomo Sarid, a leader of the group Tzav 9, an Israeli extremist group that the U.S. sanctioned in June for blocking aid to Gaza (see 2407110018 and 2406170030). The update revises identifying information for Sarid.
The Office of Foreign Assets Control last week released another video in its ongoing effort to provide guidance on U.S. sanctions programs and rules. The latest episode, released July 12, features guidance on “what it means when funds are blocked in connection with OFAC sanctions, as well as recommended steps for what to do if your funds have been blocked.”