korealaha.blogg.se - Ofac iran sanctions update

Examples of conduct that resulted in sanctions within this category, over the last year, include:

sanctions objectives (such as transactions involving Iranian oil exports), or demonstrates structured, deceptive or evasionary conduct. It is worth noting this conduct usually includes high value transactions, activity either at the core of U.S. Material assistance can include providing financial, material, or technological support for, or goods or services in support of SDNs.

Material Assistance: OFAC appeared to sanction individuals and entities that provided material assistance to SDNs most frequently.

Secondary sanctions designations were made on a number of bases, including that the person designated under secondary sanctions authorities: (i) materially assisted SDNs (ii) acted for or on behalf of SDNs (iii) operated in a sanctioned industry sector of a country subject to sectoral sanctions (iv) was owned or controlled by SDNs (v) was involved in a significant transaction involving an SDN or (vi) committed conduct that fell into multiple categories. Next, we analyzed OFAC’s stated reasons for making each secondary sanctions designation. In the last year, it appears that approximately 59% of secondary sanctions were directed toward entities. Next, we considered whether OFAC sanctioned an entity, or an individual, natural person. The top three most frequently cited executive orders were Iran, Russia, and Iran, respectively. Within these three country programs, we compared the specific executive order that OFAC cited in its designation announcement. Finally, OFAC appeared to designate secondary sanctions pursuant to the Venezuela program least frequently.

Second, OFAC also designated individuals and entities pursuant to the Russia/ Ukraine program fairly frequently. By far, OFAC made secondary sanctions designations pursuant to the Iran program most frequently. This article analyzes trends in OFAC’s secondary sanctions designation practices over the last year.įirst, we compared the designations of secondary sanctions by country program. First utilized on a broad basis under OFAC’s Iran sanctions programs, secondary sanctions have seen broader use recently under the Russia and Venezuela sanctions programs.

In recent years, OFAC has increasingly used secondary sanctions – the threat of being placed on a US sanctions list on the basis of dealings with US-sanctioned persons or jurisdictions – to attempt to regulate the conduct of non US persons.