One Year into Russian Invasion of Ukraine: New Russia-Related Sanctions
Exactly one year since the invasion of Ukraine, on February 24th 2023, the White House, in coordination with other G7 leaders (Canada, France, Germany, Italy, Japan, and the United Kingdom), announced the newest round of sanctionsagainst key revenue generating sectors for Russia. In efforts to further degrade Russia’s economy and diminish its ability to wage war against Ukraine, the action newly targets over 200 individuals and entities including Russian firms, banks, manufacturers, and officials that helped Russia evade earlier sanctions throughout the war. Including members of the European Union, more than 30 countries representing more than half the world’s economy have already imposed unprecedented sanctions on the Russian economy, making it the most sanctioned nation in the world.
The U.S. Department of Treasury Steps in to Patrol Petroleum
The US Treasury’s Office of Foreign Assets Control (OFAC) has sanctioned nine entities involved in the production, sale, and shipment of Iranian petrochemicals and petroleum to buyers in Asia, in violation of US sanctions. Six Iran-based petrochemical manufacturers and three firms in Malaysia and Singapore have been targeted for facilitating the sale and shipment of petroleum and petrochemicals on behalf of Triliance Petrochemical Co. Ltd., which OFAC previously designated for facilitating the sale of Iranian petroleum products. The sanctions are aimed at targeting Tehran’s sources of illicit revenue, and all property and interests in property of the targeted entities must be blocked and reported to OFAC.
The OFAC Continues to Enforce Strict Sanctions on Cryptocurrency Mixers
Recently the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) added Tornado Cash to its Specially Designated National List. As part of enforcement efforts, the list contains individuals and companies that have been owned or transacted with targeted countries or organizations that may prove to be a threat to the United States. This action gives rise to questions regarding “secondary” sanctions/designated risk, and the effect this policy has on smart contracts and other protocols.
Enforcing Foreign Compliance with U.S. Regulations
Compliance standards in the United States come from the laws and policies enacted by the government and its related agencies. Administering U.S. standards on foreign institutions, public or private, poses a unique challenge. Our public and private companies are held accountable by federal, state, local, or agency rules, as well as the guidelines providedby the United States Sentencing Commission. But foreign organizations, in theory, have no real obligation to follow our lead. There have been several notable attempts in recent years to enact legislation on foreign organizations and impose sanctions for noncompliance, and it is likely a continuing trend as the compliance industry grows.