Episode 139

6th January – 12th January 2025

Sanctions

The sanctions news this week starts in the US where the Department of the Treasury’s Office of Foreign Assets Control (‘OFAC’) has sanctioned ‘Mohammad Hamdan Daglo Mousa (Hemedti), the leader of Sudan’s Rapid Support Forces, under Executive Order (E.O.) 14098, “Imposing Sanctions on Certain Persons Destabilizing Sudan and Undermining the Goal of a Democratic Transition.”’ OFAC has also sanctioned Antal Rogán, an aide to the Hungarian prime minister, Viktor Orbán. The move is in response to alleged corruption by Rogán, where assets have been obtained for himself and allies.

In other news from the US this week, OFAC has issued a licence in relation to the Syrian sanctions regime ‘to help ensure that sanctions do not impede essential services and continuity of governance functions across Syria, including the provision of electricity, energy, water, and sanitation.’ This move builds on pre-existing authorisation in relation to the Syrian sanctions regime.

In the UK, the Office of Financial Sanctions Implementation (‘OFSI’) has amended a licence in place respecting sanctioned Russian bank, VTB Bank PJSC, and a further licence ‘to clarify that statutory auditors may receive permitted payments made by UK designated persons or persons acting on UK designated persons behalf.’ Then, later in the week, a new general licence in relation to Russian Oil Exempt Projects.

OFSI has also amended the listing of Zapchasttrade LLP on the Russia Financial Sanctions Regime. In additions, OFAC has announced that ‘Blood and Honour’, a right-wing extremist group, has been added to the Counter-Terrorism (Domestic) regime, and it is now subject to an asset freeze. Further additions have been made to the Venezuelan financial sanctions regime, and PJSC Surgutneftegas and Gazprom Neft have been added to the Russia financial sanctions regime.

The big news from the UK this week is the announcement by the Foreign, Commonwealth & Development Office (‘FCDO’) that it ‘plans to develop a new sanctions regime aimed at combating people smuggling and irregular migration. This world-first standalone sanctions regime is expected to be implemented within a year, allowing the UK to target individuals and entities facilitating dangerous journeys…. The regime will work alongside existing international efforts and upcoming border security legislation to disrupt criminal networks and their finances. This development follows recent enhancements to Serious Crime Prevention Orders, enabling swift action against suspected smugglers through travel bans and communication restrictions.’

And finally from the UK, the government has issued guidance ‘intended to support UK exporters in understanding Russian circumvention practices and in reducing the risk of their business being targeted by those seeking to evade sanctions.’

Money Laundering

On money laundering news this week, the Gambling Commission in the UK has fined Greentube Alderney Limited (‘Greentube’), trading as Admiral Casino, £1m for anti-money laundering failings and, as these findings often do, also in relation to its corporate social responsibilities. This is the second finding against this operator as it was fined for similar failings in 2021. Greentube did not always scrutinise ‘available information upon receipt, or in a timely manner, leading to an avoidable delay in the identification and potential escalation of money laundering and/or terrorist financing risks’; did not always ‘follow its own policy regarding what it refers to as “risky occupations”’; finally, it did not always fully investigate and escalate ‘accounts showing apparent links to other accounts in a timely manner leading to an avoidable delay in investigating, escalating and acting to mitigate the potential risk of accounts being potentially funded or controlled by a different account holder for similar breaches.’

In news from Portugal, Novo Banco has dismissed its chief risk officer, Carlos Jorge Ferreira Brandao, reported concerns respecting his conduct to Portugal's banking regulator, and filed a complaint to the Public Prosecutor's Office. The action taken follows an internal investigation undertaken by the bank.

Cyber Crime

On cybercrime news this week, the Office of Foreign Assets Control (‘OFAC’) in the US has sanctioned ‘Integrity Technology Group, Incorporated (Integrity Tech), a Beijing-based cybersecurity company, for its role in multiple computer intrusion incidents against U.S. victims. These incidents have been publicly attributed to Flax Typhoon, a Chinese malicious state-sponsored cyber group that has been active since at least 2021, often targeting organizations within U.S. critical infrastructure sectors.'