OCR Global Trade Brief – December 2023

U.S. Treasury imposes additional price cap-related sanctions 


The U.S. Department of the Treasury today issued a release announcing that the Office of Foreign Assets Control (OFAC) is imposing sanctions on three entities and identifying as blocked property three vessels that used Price Cap Coalition* services while carrying Russian crude oil above the Coalition-agreed price cap.


These sanctions build on Treasury’s previous actions in October and November of this year and represent once again Treasury’s commitment, alongside its Coalition partners, to responsibly reduce oil revenues that the Russian government uses to fund its war against Ukraine.


Source: https://home.treasury.gov/news/press-releases/jy1940



Treasury Targets Russian Defense Procurement Network


 U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is targeting a network led by Belgium-based Hans De Geetere that is involved in procuring electronics with military applications for Russian end-users. The network consists of nine entities and five individuals based in Russia, Belgium, Cyprus, Sweden, Hong Kong, and the Netherlands.


Concurrent with OFAC’s action, the U.S. Department of Justice (DOJ) unsealed two separate indictments against Hans De Geetere related to his years-long scheme to unlawfully export sensitive, military-grade technology from the United States to end users located in the People’s Republic of China (PRC) and the Russian Federation. The U.S. Department of Commerce is also concurrently adding Hans De Geetere and five entities to the Bureau of Industry and Security (BIS) Entity List. Additionally, Belgian authorities took action against De Geetere on charges related to his global illicit procurement scheme.


Source: https://home.treasury.gov/news/press-releases/jy1948



Settlement Agreement between the U.S. Department of the Treasury’s Office of Foreign Assets Control and Nasdaq, Inc.


The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) today announced a settlement with Nasdaq, Inc.  Nasdaq agreed to remit $4,040,923 to settle its potential civil liability for a former wholly owned foreign subsidiary’s apparent violations of sanctions on Iran.  This former subsidiary engaged in the exportation of services to Iran and the Government of Iran, thereby committing 151 apparent violations of OFAC sanctions on Iran.  The settlement amount reflects OFAC’s determination that Nasdaq’s conduct was non-egregious and voluntarily self-disclosed


Source: https://ofac.treasury.gov/recent-actions/20231208_33



Treasury Imposes Sanctions on More Than 150 Individuals and Entities Supplying Russia’s Military-Industrial Base


Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), is implementing the commitments made by G7 Leaders by taking action against third-country actors who materially support Russia’s war; targeting Russian military procurement networks and those who help Russia acquire machine tools, equipment, and key inputs; and further curtailing Russia’s use of the international financial system to further its war in Ukraine. 


Concurrently, the Department of State is imposing sanctions on over 100 entities and individuals, including those engaged in sanctions evasion in numerous third countries, complicit in furthering Russia’s ability to wage its war against Ukraine, and responsible for bolstering Russia’s future energy production and export capacity.


OFAC is designating a network of four entities and nine individuals based in the PRC, the Russian Federation, Hong Kong, and Pakistan involved in the facilitation and procurement of Chinese-manufactured weapons and technologies to Russia. 


Source: https://home.treasury.gov/news/press-releases/jy1978



Settlement Agreement between the U.S. Department of the Treasury’s Office of Foreign Assets Control and CoinList Markets LLC


The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) today announced a $1,207,830 settlement with CoinList Markets LLC.  CoinList agreed to settle its potential civil liability arising from processing 989 transactions on behalf of users ordinarily resident in Crimea between April 2020 and May 2022, in apparent violation of OFAC’s Russia/Ukraine sanctions.  The settlement amount reflects OFAC’s determination that CoinList’s conduct was non-egregious and not voluntarily self-disclosed.  


Source: https://home.treasury.gov/news/press-releases/jy1978



U.S. BIS renews temporary denial of export privileges of three Russian airlines for one year


The Bureau of Industry and Security (BIS) of the U.S. Department of Commerce released for publication in the Federal Register three notices renewing the temporary denial of export privileges of Russian airlines (Pobeda Airlines, Nordwind Airlines, Siberian Airlines d/b/a S7 Airlines). All three orders were originally issued in June 2022 and renewed twice—in December 2022 and June 2023. According to the notices, evidence presented by BIS demonstrates that:


The airlines acted in violation of the Export Administration Regulations (EAR) and the temporary denial order (TDO). Violations were significant, deliberate, and covert. There is a likelihood of imminent violations.


Therefore, the orders are renewed—effective immediately—and will remain in effect for one year. The renewal for an extended period is appropriate because the airlines have engaged in a pattern of repeated, ongoing and/or continuous apparent violations of the EAR.


Source: https://public-inspection.federalregister.gov/2023-27474.pdf



U.S. And UK Target Additional Hamas Finance Officials and Representatives


Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed a fourth round of sanctions on Hamas since the October 7 terrorist attack on Israel. Today’s action targets key officials who perpetuate Hamas’s violent agenda by representing the group’s interests abroad and managing its finances. OFAC closely coordinated with the United Kingdom to concurrently designate several key Hamas officials.


This action builds on OFAC’s recent joint designations with the United Kingdom on November 14, targeting Hamas leaders and financiers, as well as U.S. actions on October 27, targeting sources of Hamas support and financing; October 18, targeting Hamas operatives and financial facilitators; and May 2022, designating officials and companies involved in managing Hamas’s secret international investment portfolio. Individuals targeted today operate as key officials of Hamas and have also provided financial support to the terrorist group. These individuals are being designated pursuant to Executive Order (E.O.) 13224, as amended, which targets terrorist groups and their supporters.


Source: https://home.treasury.gov/news/press-releases/jy1981

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OFAC continues to disrupt the networks and channels through which Russia attempts to sustain its beleaguered military. These sanctions focus on individuals and entities abetting Russia’s unconscionable war against Ukraine by providing Russia with much-needed technology and equipment from third countries. Additionally, these actions take aim at Russia’s domestic industrial base, which is seeking to reinvent itself as the maintainer of Russia’s war machine. With these designations, Treasury is disrupting producers, exporters, and importers of nearly all of the high-priority items identified by the international coalition imposing sanctions and export controls on Russia.

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