The Treasury’s Office of Foreign Assets Control left out several key components of an effective compliance program in its recent sanctions compliance guide, according to a May 6 report from law firm Paul Hastings. The report said the guide should have included descriptions and instructions for “a confidential reporting process,” an "investigations process,” “disciplinary measures for employees which fail to follow the program” and “an emphasis” on mid-level employees stressing the importance of compliance instead of just senior management. The report said these components “appear in guidance documents in other areas” and "it is not clear why OFAC chose to omit these nuances … but no doubt practitioners will seek further clarification from OFAC in the weeks and months to come.” The guide, published May 6, represented an escalating step in OFAC’s effort to disseminate information about effective compliance programs, potentially allowing the agency to more successfully prosecute compliance cases (see 1905030055). The guide provides details of compliance programs that are “now all but mandatory in OFAC’s opinion,” the report said.
The Treasury’s Financial Crimes and Enforcement Network issued an update to its advisory on Venezuelan attempts to “steal, hide or launder money” in the wake of U.S.-imposed sanctions, FinCEN said in a May 3 press release. The 15-page advisory -- described as a guide for “chief risk officers,” chief compliance officers,” “sanctions analysts” and “legal departments,” among others -- provides an overview of U.S. sanctions against Venezuela and details the country’s attempts to avoid them. The guide also provides “financial red flags” to help companies report “suspicious activity that may be indicative of corruption by Venezuelan senior political figures.”
The U.S. is renewing five of seven Iran-related sanctions waivers that allow Russia and European countries to “conduct civilian nuclear cooperation with Iran,” according to a May 3 report from the Associated Press. The waivers were extended by Secretary of State Mike Pompeo for 90 days to allow work at “several Iranian nuclear sites to continue without U.S. penalties,” the AP reported.
The United Nations Security Council added Mohammed Masood Azhar Alvi, a Pakistan native, to its ISIL and Al-Qaida sanctions list, the U.N. said in a May 1 press release. U.N. said Alvi is the founder of terrorist group Jaish-i-Mohammed and the former leader of Harakat ul-Mujahidin. The sanctions include an assets freeze, travel ban and arms embargo, the U.N. said.
The Department of the Treasury is “initiating a renewal of the public certificate securing the www.treasury.gov website,” which includes the Office of Foreign Assets Control’s “sanctions list downloads,” OFAC said in a May 1 technical notice. The certificate is being replaced May 16 at 9 p.m. EDT and will take about three to six hours for the "replacement certificate to be distributed worldwide,” the notice said. “If your application pins or otherwise trusts the serial number of the existing certificate as part your application functionality, you may need to update your configuration to trust the renewed certificate,” OFAC said. Questions should be directed to O_F_A_C@treasury.gov or the tech support hotline at 1-800-540-6322.
President Donald Trump said the U.S. will place the “highest-level sanctions” and a “complete embargo” on Cuba if it does not stop “military and other operations” in Venezuela. The announcement, made April 30, came hours after Venezuelan opposition leader Juan Guaido called for a military uprising. U.S. National Security Adviser John Bolton said earlier that Cuban troops were aiding Venezuelan President Nicolas Maduro, according to the Associated Press.
The European Council renewed its sanctions on Myanmar/Burma until April 30, 2020, according to an April 29 press release from the European Union. The sanctions place a ban on exporting dual-use goods to the country and prohibit dealing in “arms and equipment that can be used for internal repression,” the release said, as well as equipment for “monitoring communications” and “military cooperation” with the Myanmar Armed Forces. The sanctions also cover 14 “high-ranking officials” in the Myanmar military who committed “serious human rights violations,” the council said.
The Treasury's Office of Foreign Assets Control is issuing regulations for sanctions surrounding foreign interference in U.S. elections, according to an April 26 notice. The regulations require the director of national intelligence to investigate any information that points to the possibility of foreign interference within 45 days after the conclusion of U.S. elections and recommend “remedial actions” for the U.S. government to take, other than sanctions. The regulations also list provisions for sanctioning those involved in election interference, including blocking any U.S.-related “property and interest.”
The Treasury’s Office of Foreign Assets Control sanctioned two Venezuelan officials who it called “corrupt [Nicolas] Maduro insiders,” according to an April 26 press release. OFAC added Jorge Alberto Arreaza Montserrat, Venezuela’s minister of Foreign Affairs, and Carol Bealexis Padilla de Arretureta, a Venezuelan court judge, to the Specially Designated Nationals List.
The Treasury’s Office of Foreign Assets Control announced a settlement of $75,375 with Haverly Systems, a New Jersey software company with offices in Texas and California, for violations of the Ukraine Related Sanctions regulations, OFAC said in an April 25 enforcement notice. Haverly violated the sanctions twice between May 2016 and January 2017 when it “dealt in new debt of greater than 90 days maturity” with JSC Rosneft, a Russian oil company that was designated under Ukraine-related sanctions, OFAC said.