Multiple users reported, starting last month, issues with downloading data files on sanctions lists from the Treasury's Office of Foreign Assets Control website after OFAC said it made changes regarding its HTTP request methods, the agency said in a March 20 notice. OFAC said the changes affected users that “leverage command line connections” to the Treasury’s website. Those who download OFAC sanctions data files “manually via browser” are not be impacted by the change, according to the notice. The change allows for users to only request sanctions data files via HTTP using GET commands, as opposed to both GET and POST commands, OFAC said. The agency said the change is permanent and was “made to improve the security for public file repositories.” The agency said questions about the change should be emailed to O_F_A_C@treasury.gov; OFAC’s technical support hotline is at 1-800-540-6322 (menu option 8).
OFAC sanction activity
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.”
Oleg Deripaska, a Russian businessman who was sanctioned by the U.S. in 2018, sued the Treasury Department last week, alleging its sanctions rely on “unsubstantiated” allegations and have led to the “utter devastation” of his “wealth, reputation, and economic livelihood,” according to court documents. The suit, filed March 15, requests that the U.S. District Court for the District of Columbia order Treasury's Office of Foreign Assets Control to remove the sanctions. It names Treasury Secretary Steven Mnuchin, Treasury Department OFAC Director Andrea Gacki, the Treasury Department and OFAC as defendants.
The Treasury Department's Office of Foreign Assets Control published updates to its Specially Designated Nationals List by listing nine people associated with Venezuela, according to two OFAC notices. Both notices, which will be published in the Federal Register, announce sanctions that were issued last month. The first notice lists four people with ties to Venezuela whose sanctions were first announced by OFAC on Feb. 25, and the second notice lists five people associated with Venezuela whose sanctions were announced Feb. 15.
The Treasury Department's Office of Foreign Assets Control amended a general license related to U.S. sanctions on Venezuela, according to a March 14 OFAC notice. The license allows transactions with PDV Holding and CITGO Holding, two oil companies and subsidiaries of Petroleos de Venezuela, the U.S.-sanctioned and Venezuela state-owned oil company. The license also allows transactions with PDV Holding’s and CITGO Holding’s subsidiaries. The license changes the expiration date to automatically renew on the first day of each month, the notice said, and is “valid for a period of 18 months from the effective date” of the general license “or the date of any subsequent renewal of (the license), whichever is later.” The license, General License No. 7A, replaces General License No. 7, which was issued Jan. 28.
The U.S., the European Union and Canada announced additional Russian sanctions stemming from Russia's actions in Ukraine, according to media reports and a March 15 announcement by the U.S. Treasury Department. Treasury's Office of Foreign Assets Control added six people and eight entities to its Specially Designated Nationals List, OFAC said in a notice, while Canada reportedly imposed sanctions on 114 people and 15 entities and the EU targeted eight security service officials and military commanders. Individuals or companies who trade with any of the blocked people or entities may be penalized under U.S. sanctions.
The Treasury Department's Office of Foreign Assets Control made changes to one of its sanctions lists, replacing the List of Foreign Financial Institutions Subject to Part 561 with the List of Foreign Financial Institutions Subject to Correspondent Account or Payable-Through Account (CAPTA) Sanctions, OFAC said in a March 14 notice. The new list contains foreign entities “for which the opening or maintaining of a correspondent account or a payable-through account” in the U.S. is restricted, OFAC said. Foreign entities on the list are subject to the Ukraine Freedom Support Act of 2014, the North Korea Sanctions Regulations, the Iranian Financial Sanctions Regulations and the Hizballah International Financing Prevention Act of 2015. OFAC also amended the Iran and Hizballah financial sanctions regulations to include references to CAPTA, the agency said.
Export Compliance Daily is providing readers with some of the top stories for March 5-8 in case they were missed.
The Office of Foreign Assets Control added an entity to its Specially Designated Nationals List, with a Venezuela-related designation, OFAC said in a March 11 notice. The entity, Evrofinance Mosnarbank, is associated with a Moscow address in Russia, according to the notice, and is linked to Petroleos de Venezuela, the Venezuelan state-owned and U.S.-sanctioned oil company.
The Treasury Department's Office of Foreign Assets Control amended two general licenses related to Venezuelan sanctions, OFAC said in a March 8 notice, extending the expiration date of provisions allowing transactions that involve the “wind down of certain financial contracts” with Venezuela. The first general license includes a provision that permits the divestment or transfer of Venezuelan-related bonds as long as the trades were placed before 4 p.m. on Feb. 1. The second general license allows “facilitating, clearing, and settling transactions” involving divestiture of holdings in Petroleos de Venezuela, the U.S.-sanctioned Venezuelan oil company, for all transactions that were placed before 4 p.m. on Jan. 28. Both authorizations are permitted only if divestments or transfers are made to a non-U.S. person, OFAC said. Transactions are authorized until May 10.