Based on 2022 U.S. sanctions enforcement trends, companies should make sure to scale their sanctions compliance programs along with their business expansions, continually conduct audits and make sure employees are properly trained on sanctions compliance, Morrison & Foerster said in a March 6 client alert. The alert explores some of the lessons companies can learn from the Treasury Department’s penalties last year, including that “insufficient oversight” during a merger process can lead to sanctions risks, and all companies -- large or small -- will be held to Treasury’s sanctions compliance standards.

The Office of Foreign Assets Control this week announced a host of new Iran-related sanctions, including new designations against a “shadow banking” network aiding Iranian entities and new sanctions against a network of Chinese companies with ties to the country's unmanned drone industry. The designations target 39 entities illegally allowing Iranian companies to access the international financial system and a network of five companies supporting Iran’s unmanned aerial vehicle procurement efforts.

The U.S. this week removed sanctions on a former Kazakhstan-based subsidiary of Russia’s Sberbank after the subsidiary changed ownership and asked the Treasury Department to delete the bank from its Specially Designated Nationals List. The subsidiary, now owned by the Kazakhstan government, is "one of the largest banks in Kazakhstan" and "systemically important to the Kazakhstani financial industry," a Treasury spokesperson said March 8, adding that the agency worked "closely" with the Kazakhstan government to help it complete the purchase.

The Office of Foreign Assets Control this week sanctioned eight Iranian officials and three Iranian entities for their ties to human rights abuses against women and girls. The designations target senior officials in Iran’s prison system, a top army commander, a high-ranking leader in the Islamic Revolutionary Guard Corps and others. Also sanctioned was Iranian security services supplier Naji Pas Co. and CEO Reza Asgharian; security services provider Naji Pars Amin Institute and CEO Bahram Abdollahinejad; and police equipment importer Entebagh Gostar Sepehr Co. and CEO Gholamreza Ramezanian Sani.

The U.N. Security Council last week amended one Democratic Republic of the Congo-related entry on its sanctions list. The update revises identifying and other information for Taganda Bosco, the former military commander for a political armed militia in the DRC who was convicted of war crimes by the International Criminal Court in 2021.

The U.S. last week sanctioned five Russian officials and one "expert witness" involved in the arrest and imprisonment of Russian opposition politician Vladimir Kara-Murza. The designations came after lawmakers, including Sens. Bob Menendez, D-N.J., and Jim Risch, R-Idaho, asked the administration to impose Magnitsky human rights sanctions against Russia for the arrest of Kara-Murza, who has spoken against the war in Ukraine (see 2209270021 and 2301260046).

Russia is using the United Arab Emirates as a major transhipment hub to import controlled goods, a Treasury Department official said last week. UAE companies exported more than $18 million worth of goods to sanctioned Russian entities between July and November, said Elizabeth Rosenberg, assistant secretary for terrorist financing and financial crimes. They also exported more than $5 million worth of U.S.-origin and export controlled goods to Russia June to November. Those items included “semiconductor devices” used by Russia to fight its war in Ukraine.

The Office of Foreign Assets Control this week published previously issued general licenses under its Russian Harmful Foreign Activities Sanctions Regulations. The full text of each license appears in the notice.

President Joe Biden this week extended national emergencies that authorize certain sanctions related to Venezuela, Zimbabwe and Russian actions in Ukraine. Each was renewed for one year.

The U.S. this week sanctioned six entities and 20 vessels that have helped transport or sell Iranian petroleum or petrochemical products. The designations target companies based in China, Vietnam, the United Arab Emirates and Iran, including China-based Global Marine Ship Management. Co. and Shanghai Xuanrun Shipping. Co., the State Department said. The 20 designated ships have ties to Shanghai Xuanrun Shipping, Vietnam-based Golden Lotus Oil Gas and Real Estate Joint Stock Company, and UAE-based Swedish Management Co.