The Office of Foreign Assets Control this week sanctioned 13 Sinaloa Cartel members and four Mexican companies for their ties to fentanyl trafficking. The designations, coordinated with the Mexican government, target several high-ranking cartel officials, including Sinaloa's Sonora-based “plaza boss” Juan Carlos Morgan Huerta and his adult family members.
Multinational banks are more often choosing not to authorize payments involving sanctioned jurisdictions or people, even if those payments are authorized by a general license or not subject to restrictions, said Richard Newcomb, a DLA Piper lawyer and former director for the Office of Foreign Assets Control. “Even if authorized, banks increasingly will not process a transaction involving or touching a sanctioned country or do business with anyone that has unlawfully done business with a sanctioned person or country,” Newcomb said.
Petitioning to be delisted from a sanctions regime has become increasingly difficult and often lacks transparency, both in the U.S. and Canada, trade lawyers from both countries said this week. Several lawyers, including a former high-ranking senior U.S. sanctions official, said designated people often aren’t given an adequate explanation for why they were sanctioned and therefore aren’t able to fairly challenge the basis for their designation.
An Illinois-based financial services firm reached a $206,213 settlement with the Office of Foreign Assets Control this week after the company allowed its prepaid reward card programs to be used by people in sanctioned regions, including Iran, Syria, Cuba and the Crimea region of Ukraine. OFAC said Swift Prepaid Solutions’ lack of “comprehensive geolocation controls” led to 12,391 violations of U.S. sanctions programs.
The Office of Foreign Assets Control last week sanctioned Ekaterina Zhdanova, a Russian national who the agency said has laundered money and moved funds on behalf of wealthy Russians using virtual currency.
The U.S. this week announced a spate of new Russia-related sanctions and export controls, targeting people and companies supplying Russia’s military, aiding its defense industrial complex or operating in various Russian financial, metals, government and procurement sectors. The measures include additions to the Commerce Department’s Entity List and more than 200 combined sanctions by the Treasury and State departments targeting businesses in China, the United Arab Emirates and elsewhere for sending export-controlled components to Russia.
The U.S., the U.K. and Canada issued new sanctions this week against Myanmar, targeting various entities and officials with ties to the country’s military regime and its purchase of weapons.
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The Office of Foreign Assets Control last week announced its second round of Hamas-related sanctions after the terror group’s killings in Israel earlier this month, designating more Hamas-linked officials and financial networks. The agency sanctioned people helping Hamas evade sanctions, their companies and other entities with ties to the group.
Jenner & Block partner Rachel Alpert was tapped to serve as the chief counsel to the Treasury Department's Office of Foreign Assets Control, the firm announced on Oct. 24. Alpert has worked at Jenner & Block since 2021 and has fleshed out the firm's national security, sanctions and export controls practice, along with the human rights and global strategy practice. Her practice centered around export controls and sanctions proceedings under the International Traffic in Arms Regulations, Export Administration Regulations and OFAC regulations, among other things. Prior to working at Jenner & Block, Alpert worked as an attorney-adviser to the State Department and as counsel at Latham & Watkins.