DOJ’s recent sanctions-related subpoenas of Credit Suisse Group and UBS Group are more evidence of the agency’s increasing “emphasis” on corporate enforcement, Rahman Ravelli said in an April 6 client alert. The agency launched a probe on both Swiss banks to examine whether they helped Russian oligarchs evade sanctions, Bloomberg reported last month, and Rahman Ravelli said the effort is part of a “wave of subpoenas” issued by DOJ in recent weeks.
Companies should be prepared for more “swift and persistent changes” to U.S. sanctions and export control regulations as the Biden administration continues to impose restrictions on Russia for its invasion of Ukraine, Barnes & Thornburg said in an April 4 client alert. The firm also said companies should prepare for U.S. government “inquiries into their transactions” even if they aren’t doing business in Russia or Belarus. “[T]hird-party intermediary risks are global,” it said. The Bureau of Industry and Society is one agency ramping up outreach to exporters amid a rise in new restrictions against Russia and China (see 2303240060).
The Office of Foreign Assets Control this week sanctioned Gary Bodeau, the former president of the Haitian Chamber of Deputies, for his “extensive involvement in corruption.” The agency imposed sanctions under the Global Magnitsky Human Rights Accountability Act against Bodeau, who has “created an environment that empowers illegal armed gangs and their supporters to inflict violence on the Haitian people,” said Brian Nelson, the Treasury Department’s undersecretary for terrorism and financial intelligence.
The U.S. this week sanctioned Genesis Market, one of the world’s “largest illicit marketplaces,” for illegally selling stolen data, including usernames and passwords. The marketplace is “believed” to be based in Russia, the Office of Foreign Assets Control said, where it operates as one of the “most prominent brokers of stolen credentials and other sensitive information,” including information from U.S. and international companies. Cybercriminals also have used Genesis Market to target the U.S. government, OFAC said.
The Office of Foreign Assets Control this week sanctioned Lebanese brothers Raymond Zina Rahme and Teddy Zina Rahme, along with their companies, for corruption and other activities that “contribute to the breakdown of the rule of law in Lebanon.” OFAC said the brothers use United Arab Emirates-based ZR Energy DMCC and Lebanon-based ZR Group Holding SAL and ZR Logistics SAL to win government contracts through a “highly opaque public tendering process.”
The Office of Foreign Assets Control this week published two sets of previously issued general licenses under its Venezuela sanctions regime. The full text of each license appears in the respective notice.
Australia last week released the public submissions it received as it reviews its autonomous sanctions regulations, which are scheduled to expire April 1, 2024. Submissions came from Australian financial institutions, law firms, universities and others.
The Office of Foreign Assets Control last week sanctioned Tabacalera del Este, a Paraguay-based cigarette manufacturer, and issued a new general license authorizing certain transactions with the company. OFAC said Tabacalera is owned 50% or more by former Paraguayan President Horacio Manuel Cartes Jara, who was sanctioned by the agency in January for corruption, along with another of his companies, Tabacos USA (see 2301260073).
The State Department this week published its 2022 Global Magnitsky Human Rights Accountability Act Annual Report in the Federal Register, detailing actions the agency took to impose Magnitsky sanctions that year, which included 35 foreign person designations. The report lists each of the designations, including why they were designated.
The Office of Foreign Assets Control this week sanctioned Slovakian national Ashot Mkrtychev for trying to facilitate arms deals between Russia and North Korea. Mkrtychev worked with North Korean officials, including as recently as this year, to “obtain” more than two dozen kinds of weapons and munitions for Russia in exchange for commercial aircraft, raw materials and other commodities, OFAC said. The agency said Mkrtychev negotiated a “mutually beneficial cooperation” agreement between North Korea and Russia “to include financial payments and barter arrangements,” and “confirmed Russia’s readiness to receive military equipment from [North Korea] with senior Russian officials.”