An OFAC Compliance Checklist For Ransomware Payments By
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Primary area of interest Law360 (February 2, 2021, 5:43 PM EST)
Tuesday, 23 March 2021, 14:36
NBU warns of risks of cooperation with citizens subject to U.S. sanctions
27.01.2021 12:35
Ukrinform
The National Bank of Ukraine (NBU) has informed banks about the risks of cooperation with Ukrainian citizens who have recently been sanctioned by the United States, including Ukrainian MP Oleksandr Dubinsky.
This is stated in a letter from the NBU on the inclusion of individuals and legal entities from Ukraine in the U.S. sanctions list, which was sent to Ukrainian banks, the Independent Association of Ukrainian Banks, the Association of Ukrainian Banks, and the Financial Services Markets Association. According to information received from the Ministry of Foreign Affairs of Ukraine, the United States on January 11, 2021 included seven citizens of Ukraine and four media organizations registered in Ukraine in the U.S. Treasury Department s Specially Designated Nationals and Blocked Persons List (OFAC SDN List) in accordance with Executive Order 13848
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[co-authors: Nick Russell, and Alasdair Kan]
Key Points
The U.S. government has recently imposed controls pertaining to “Communist Chinese Military Companies” (CCMCs or “1237 entities”); Chinese “Military End Users” (MEUs); and Chinese “Military-Intelligence End Users” (MIEUs). The U.S. government has also been adding Chinese companies to the Entity List based on concerns regarding the companies’ relationships to the Chinese military industrial complex.
Although the names and underlying policy concerns are similar, the scope and source of the prohibitions regarding each set of Chinese entities are quite different. Companies on one of the lists are not automatically on others, but overlap is possible as the lists evolve. These lists are in addition to the Chinese entities that are on the Unverified List (UVLs), the Denied Persons List (DPLs), and the Specially Designated Nationals and Blocked Persons List (SDNs).
January 13, 2021
Washington – The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) took action today against two organizations, along with their leaders and subsidiaries, controlled by the Supreme Leader of Iran, the Execution of Imam Khomeini’s Order (EIKO), and Astan Quds Razavi (AQR). While purportedly charitable organizations (bonyads), EIKO and AQR control large swaths of the Iranian economy, including assets expropriated from political dissidents and religious minorities, to the benefit of Supreme Leader Ali Khamenei and senior Iranian government officials. Alongside the previously designated Bonyad Mostazafan, itself controlled by the Supreme Leader, and the IRGC-owned Khatam al-Anbiya, AQR and EIKO are said to control more than half of the Iranian economy.