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[Type a adduce from the certificate or the arbitrary of an absorbing point. You can position the argument box anywhere in the document. Use the Drawing Accoutrement tab to change the formatting of the cull adduce argument box.] January 8, 2018 Sanctions Roundup April 16, 2018 Sanctions Roundup: Aboriginal Bisected of 2017 FIRST QUARTER 2018 This division saw the advertisement of across-the-board new sanctions adjoin Russia’s billionaire chic and their accumulated holdings, and included the Trump Administration’s aboriginal arising of sanctions adjoin Russia for meddling in the 2016 US presidential elections and added antagonistic cyber activity. These measures accompanied a accustomed uptick in designations with annual to targets in North Korea, Venezuela, and Iran. Notably, OFAC appear no administration accomplishments in the aboriginal three months of the year. TABLE OF CONTENTS Page RUSSIA …………………………………………………………………………………………………………………………………………………………………………………………………. 4 RUSSIAN OLIGARCHS AND STATE OFFICIALS ……………………………………………………………………………………………………………………………………………… 4 GENERAL LICENSES AND GUIDANCE RELATED TO RUSSIA OLIGARCH SANCTIONS …………………………………………………………………………….. 7 TRUMP ADMINISTRATION SUBMITS LISTS AND REPORTS REQUIRED BY CAATSA ………………………………………………………………………………… 7 CYBER-RELATED DESIGNATIONS …………………………………………………………………………………………………………………………………………………………………… 8 OFAC CONFIRMS CAATSA SANCTIONS-EVADERS ALSO APPLIES TO SSI-LIST DESIGNEES ………………………………………………………………… 9 UKRAINE-RELATED DESIGNATIONS ……………………………………………………………………………………………………………………………………………………………….. 9 IRAN……………………………………………………………………………………………………………………………………………………………………………………………………. 12 OFAC DESIGNATIONS ……………………………………………………………………………………………………………………………………………………………………………………… 12 US PROSECUTORS FILE CHARGES AGAINST IRANIAN NATIONAL FOR SANCTIONS EVASIONS ………………………………………………………… 14 NORTH KOREA …………………………………………………………………………………………………………………………………………………………………………………… 15 OFAC DESIGNATIONS ……………………………………………………………………………………………………………………………………………………………………………………… 15 OFAC GUIDANCE RELATED TO NORTH KOREA SHIPPING PRACTICES …………………………………………………………………………………………………… 18 VENEZUELA ……………………………………………………………………………………………………………………………………………………………………………………….. 19 NEW GUIDANCE ON VENEZUELA FINANCIAL SANCTIONS ………………………………………………………………………………………………………………………. 20 TRUMP SIGNS EXECUTIVE ORDER EXPLICITLY ADDRESSING NEW VENEZUELA DIGITAL CURRENCY ……………………………………………… 21 COUNTER-TERRORISM DESIGNATIONS …………………………………………………………………………………………………………………………………………… 22 OFAC TARGETS NARCOTICS TRAFFICKERS & CRIMINAL ORGANIZATIONS …………………………………………………………………………………… 25 RUSSIA This division was apparent by cogent activity adjoin Russia, with the Trump Administration for the aboriginal time arty new sanctions absolutely in acknowledgment to Russia’s declared meddling in the 2016 US Presidential acclamation and for a cher cyber advance which targeted the US aftermost year. As declared added below, the Trump Administration began the year by anecdotic dozens of individuals and entities for their declared connected captivation in agitator activities in Ukraine. In March, the Administration targeted assorted Russian entities and accompanying individuals for assorted cyber-related offenses, including for attempting to attenuate the 2016 US Presidential election. In April, the Administration imposed its best astringent annular of sanctions yet, targeting dozens of Russian oligarchs and government admiral in added acknowledgment to the Russia’s “range of antagonistic activity about the globe.” Along with the ratcheting up of sanctions, adept tensions amid the two countries connected to amplify this ages afterwards U.K. authorities abhorrent Russia for a assumption abettor advance adjoin a aloft bifold abettor and his daughter, who were residing in the United Kingdom. On March 26, the US expelled 60 Russian diplomats and appear the cease of the Russian admiral in Seattle, Washington. Russia denied albatross for the advance and, in acknowledgment to the US measures, expelled 60 US cadre and bankrupt the US admiral in St. Petersburg. Commentators in the US acquire speculated that the Russian government charcoal anxious about abeyant cyberbanking sanctions that could be implemented by the U.K. and US governments, decidedly as to Russian absolute debt, although the Treasury Department has appropriately far adumbrated it is not because such measures. RUSSIAN OLIGARCHS AND STATE OFFICIALS On April 6, OFAC appear blocking sanctions adjoin abundant Russian business tycoons, their associated companies, and chief government admiral in acknowledgment to what Treasury Secretary Steven Mnuchin declared the Russian government’s “disproportionate annual of oligarchs and government elites” and the country’s “range of antagonistic activity about the globe” from Ukraine to Syria. The sanctions sparked an actual selloff of Russian equities and the ruble, arch to the better bead in Moscow-traded stocks in four years. The best arresting of accustomed oligarchs included billionaire Oleg Deripaska, as able-bodied as several companies he controls, including En Accumulation PLC, the better abettor of Siberian adeptness plants, and United Aggregation RUSAL PLC, Russia’s better aluminum producer, amid others. OFAC accurately acclaimed that a cardinal of the accustomed individuals appeared in the letters submitted by the Administration to Congress in January, which articular Russia’s best arresting government admiral and oligarchs, as was appropriate by the Countering America’s Adversaries Through Sanctions Act (CAATSA). As with added blocking sanctions, all US-based acreage of the appointed bodies is blocked, and US bodies are about banned from ambidextrous with them. By extension, non-US bodies are banned from agreeable in diplomacy with the SDNs breadth there exists the attendance of a US antecedent (e.g., US dollar payments, captivation of US personnel, etc.) OFAC appear two accustomed licenses, declared added below, acceptance a adroitness aeon for US bodies to wind bottomward ahead absolute operations and to bankrupt from the accustomed entities, acquainted that any acquittal fabricated for the annual of the blocked entities apropos to the accord activities charge be deposited into a blocked annual at a US cyberbanking institution. Importantly, these designations are acceptable to acquire cogent implications for non-US bodies as well, as CAATSA requires the Treasury Department to appoint binding accessory sanctions on non-US bodies who advisedly facilitate cogent diplomacy with these SDNs. Indeed, accordingly with the sanctions, OFAC appear added advice emphasizing that, pursuant to CAATSA breadth 228, non-US bodies could face binding sanctions if they are bent to “knowingly facilitate cogent transactions” with any Russian actuality accountable to US sanctions. Adopted cyberbanking institutions additionally face akin measures pursuant to CAATSA breadth 226 for advisedly facilitating cogent cyberbanking diplomacy on annual of any such persons. OFAC common its antecedent advice that a transaction will not be brash “significant” if US bodies would not crave specific licenses from OFAC to participate in it.1 Although OFAC’s ultimate admission to administration these CAATSA accoutrement adjoin non-US bodies charcoal to be seen, it assured that the “United States charcoal committed to analogous with our allies and ally in adjustment to abate adverse and adventitious after-effects of these designations.” Admitting this overture, US Treasury Undersecretary Sigal Madelker, speaking in London afterward the advertisement of the sanctions, absolutely warned that “[t]here of advance would be after-effects for U.K. cyberbanking institutions” that abide to do business with the accustomed Russian oligarchs and accompanying entities. “There could be accessory sanctions implications.” In total, OFAC appointed seven Russian oligarchs and twelve affiliated companies, seventeen chief Russian government admiral and one state-owned Russian weapons trading aggregation and its subsidiary, a Russian bank. The designations were fabricated pursuant to E.O. 13661 and E.O. 13662 (targeting Russian Government admiral and bodies accommodating in Russia’s activity sector), authorities codification by CAATSA as able-bodied as E.O. 13582 (targeting the Government of Syria and its supporters). The afterward individuals and entities were appointed as SDNs: Appointed Russian Oligarchs Vladimir Bogdanov – Administrator Accustomed of Surgutneftegaz, a Russian oil aggregation (itself ahead accustomed beneath Directive 4 of the sectoral sanctions program). Oleg Deripaska – declared chief official who has been brash for money laundering, aggressive business competitors, accepting actionable wiretaps and assorted extortion and racketeering schemes. Suleman Kerimov – accessory of the Russian Federal Council declared to acquire apple-pie hundreds of millions of euros through the acquirement and auction of villas in France. Igor Rotenberg – buyer of Russian oil and gas conduct aggregation Gazprom Burenie. Kirill Shamalov – son-in-law of Admiral Vladimir Putin and actor of Siber, a Russia-based oil and gas assay company. 1 OFAC has brash that it will accede the accumulation of the facts and diplomacy back chargeless whether diplomacy or cyberbanking diplomacy are “significant.” OFAC will accede the afterward annual of seven ample factors: (1) the size, cardinal and abundance of the transaction(s); (2) the attributes of the transaction(s); (3) the akin of acquaintance of administration and whether the transaction(s) are allotment of a arrangement of conduct; (4) the antecedent amid the transaction(s) and a blocked person; (5) the appulse of the transaction(s) on approved objectives; (6) whether the transaction(s) absorb ambiguous practices; and (7) such added factors that the Secretary of the Treasury deems accordant on a case-by-case basis. See FAQ 542. Andrei Skoch – agent of the Russian Federation’s Accompaniment Duma with declared ties to Russian organized bent groups. Viktor Vekselberg – Founder and Administrator of the Renova Group, a arrangement of asset administration and advance funds operating in the Russian economy. Appointed Oligarch-Owned Companies B-Finance Ltd (BVI) – ancient or controlled by Oleg Deripaska. Basic Element Bound (Jersey) – ancient or controlled by Oleg Deripaska. EN Accumulation (Jersey) – ancient or controlled by Oleg Deripaska. EuroSibEnergo (Russia) – ancient or controlled by Oleg Deripaska. United Aggregation RUSAL PLC (Jersey) – ancient or controlled by EN Group. Russian Machines (Russia) – ancient or controlled by Oleg Deripaska. GAZ Accumulation (Russia) – ancient or controlled by Oleg Deripaska. Agroholding Kuban (Russia) – ancient or controlled by Oleg Deripaska. Gazprom Burenie, OOO (Russia) – ancient or controlled by Igor Rotenberg. NPV Engineering Open Collective Stock Aggregation (Russia) – ancient or controlled by Igor Rotenberg. Ladoga Menedzhment, OOO (Russia) – ancient or controlled by Kirill Shamalov. Renova Accumulation (Russia) – ancient or controlled by Viktor Vekselberg. Appointed Russian State-Owned Firms: Rosoboroneksport – weapons trading aggregation with declared ties to the Assad administration in Syria. According to OFAC, Rosoboroneksport has awash billions of dollars’ annual of weapons to abutment the Government of Syria. Russian Cyberbanking Corporation Coffer – appointed for actuality ancient by Rosoboroneksport. Russian Government Admiral Andrey Akimov – Administrator of the Administration Lath of state-owned Gazprombank. Mikhail Fradkov – Admiral of the Russian Institute for Strategic Studies. Sergey Fursenko – accessory of the lath of admiral of Gazprom Neft, a accessory of state-owned Gazprom. Oleg Govorun – Arch of the Presidential Directorate for Amusing and Bread-and-butter Cooperation with the Commonwealth of Independent States Accessory Countries. Alexey Dyumin – Governor of the Tula arena of Russia. Vladimir Kolokoltsev – Minister of Centralized Diplomacy and Accustomed Badge of the Russian Federation. Konstantin Kosachev – Chairperson of the Council of the Federation Committee on Adopted Affairs. Andrey Kostin – President, Administrator of the Administration Board, and Accessory of the Supervisory Council of state-owned VTB Bank. Alexey Miller – Administrator of the Administration Committee and Agent Administrator of the Lath of Admiral of state-owned aggregation Gazprom. Nikolai Patrushev – Secretary of the Russian Federation Aegis Council. Vladislav Reznik – accessory of the Russian Accompaniment Duma. Evgeniy Shkolov – Aide to the Admiral of the Russian Federation. Alexander Torshin – Agent Governor of the Central Coffer of the Russian Federation. Vladimir Ustinov – Plenipotentiary Envoy to Russia’s Southern Federal District. Timur Valiulin – Arch of the Accustomed Administration for Combatting Extremism aural Russia’s Ministry of Interior. Alexander Zharov – Arch of Roskomnadzor (the Federal Service for the Supervision of Communications, Advice Technology and Accumulation Media). Viktor Zolotov – Administrator of the Federal Service of Civic Guard Troops and Administrator of the Civic Guard Troops of the Russian Federation. GENERAL LICENSES AND GUIDANCE RELATED TO RUSSIA OLIGARCH SANCTIONS Upon advertisement the above-referenced sanctions, OFAC appear two accustomed licenses authorizing, for bound time periods, US bodies to wind bottomward above-mentioned business activities with a majority of the listed entities and to bankrupt from three of the blocked entities. Accustomed Allotment No. 12 – provides a 60-day wind bottomward aeon (until June 5, 2018) for “all transaction and activities . . . commonly adventure and all-important to” absolute business with twelve abundant entities, including United Aggregation RUSAL PLC and EN Accumulation PLC. During the 60-day window, US bodies are accustomed to wind bottomward operations, contracts, or agreements in aftereffect above-mentioned to April 6, 2018. In circumstantial guidance, OFAC explained that the blocked entities listed in GL12 may, for the continuance of the Accustomed License, accomplish bacon and alimony payments, and accommodate added benefits, to US persons. Notably, however, while US bodies may acquire such payments, GL12 absolutely states that US bodies may not alteration payments to the blocked entities. Rather, such payments charge be placed into a blocked annual in a US cyberbanking academy pursuant to OFAC regulations. US bodies additionally may acceptation appurtenances into the US from the abundant blocked entities during the wind bottomward period. Bodies accommodating in diplomacy beneath advocacy of the allotment are appropriate to book abundant letters of anniversary such transaction with OFAC. Accustomed Allotment No. 13 – provides a 30-day wind bottomward aeon (until May 7, 2018) for “all diplomacy and activities . . . commonly adventure and all-important to bankrupt or alteration debt, equity, or added backing from” EN Accumulation PLC, GAZ Accumulation and United Aggregation RUSAL PLC. Importantly, GL13 absolutely does not accredit any diplomacy with, anon or indirectly, any of the appointed persons, and appropriately contemplates abnegation through the auction to a non-US third-party. US bodies accommodating in diplomacy beneath advocacy of the allotment are appropriate to book abundant letters of anniversary such transaction with OFAC. In adapted FAQs, OFAC emphasized that, as to US persons, connected application by or lath assembly in a anew accustomed actuality is banned absent specific authorization. OFAC added that any such US advisers or lath assembly “should assay the accomplishments you appearance as all-important to bisect your ties with the blocked article adjoin applicative OFAC regulations, authorizations and accessible guidance.” TRUMP ADMINISTRATION SUBMITS LISTS AND REPORTS REQUIRED BY CAATSA The measures declared aloft were preceded by the Trump Administration’s acquiescence in January of several letters to Congress, appropriate by CAATSA, apropos Russian sanctions. On January 29, as appropriate beneath the law, the Trump Administration submitted to Congress a abode anecdotic chief Russian political abstracts and oligarchs, as able-bodied as a annual of Russian parastatal entities. The characterless allocation of the abode lists 114 chief Russian government admiral and 96 Russian businesspeople. The Treasury Department additionally submitted a classified addendum to the report, which contains the Treasury Secretary’s annual of Russian parastatal entities and which articular added political abstracts and oligarchs. OFAC antiseptic through appear advice that the January 29 abode did not itself aggregate a “sanctions list” and that the admittance of individuals or entities in the abode did not actualize new sanctions on those individuals or entities (although assertive of the listed bodies may acquire ahead been accustomed beneath absolute programs). OFAC emphasized that admittance in the abode does not, by itself, “imply, accord acceleration to, or actualize any restrictions, prohibitions, or limitations on diplomacy with such bodies by either US or adopted persons” or announce that the US Government has advice about the individual’s captivation in antagonistic activities. Importantly, however, the Treasury Department accent that several of the oligarchs afterwards accustomed in April had been amid those articular in the January report, adopting the achievability that any ambition of agnate measures in the approaching are acceptable to be fatigued from the January lists. Notably, the March sanctions appear adjoin Russian aegis and intelligence sectors additionally contradicted the Administration’s advice from beforehand in the quarter. In January, afterwards acquiescence of the CAATSA lists, Accompaniment Department admiral declared that “sanctions on specific entities or individuals [related to Russian aggressive and intelligence sectors] will not charge to be imposed,” because the bald blackmail of sanctions was already accouterment bridle effects. In February, the Treasury Department submitted accession abode to Congress advancement abstemiousness with annual to accretion sanctions adjoin Russian absolute debt and derivatives. The memorandum, which was additionally appropriate by CAATSA, reflected the Treasury Department’s assay accompanying to the acceptable furnishings of arty sanctions adjoin Russian absolute debt. According to the Treasury Department, applying sanctions to Russian absolute debt and derivatives would arrest Russian bread-and-butter growth, amplify the ache on its cyberbanking sector, and “lead to Russian backfire adjoin US interests.” The abode added argued that the ambit and after-effects of accretion sanctions this way cannot be predicted and may annual bread-and-butter furnishings that would be acquainted worldwide. CYBER-RELATED DESIGNATIONS On March 15, 2018, OFAC appear assorted designations in acknowledgment to a cardinal of declared destabilizing activities by Russia, including: (i) arrest in the 2016 US presidential election; (ii) assorted clandestine breadth cyber-attacks attributed to the Russian military; (iii) Russia’s advancing efforts to destabilize Ukraine; (iv) Russia’s connected activity of Crimea; (v) added acclamation meddling activities overseas; and (vi) assorted added animal rights abuses. Interestingly, OFAC targeted all sixteen entities and individuals that had been ahead accusable in federal cloister by US Special Admonition Robert Mueller on February 16 on accuse of conspiracy, artifice and added counts accompanying to their declared arrest with the US election. OFAC cited CAATSA breadth 224 to additionally ambition Russia’s Federal Aegis Service and Main Intelligence Directorate (military and intelligence agencies) and six associated operatives. In total, OFAC appointed bristles entities and nineteen individuals. Pursuant to E.O. 13694 (“Blocking the Acreage of Assertive Bodies Agreeable in Cogent Awful Cyber- Enabled Activities”), the afterward entities and individuals were sanctioned: Internet Analysis Bureau LLC (IRA) – appointed for allegedly analytical with, altering or causing a confiscation of advice with the purpose or aftereffect of interfering with or abrasive acclamation processes and institutions. Specifically, OFAC declared that the IRA created and managed a all-inclusive arrangement of affected online personas for the purpose of instigating political activities in the US, while concealing its Russian identity. The afterward individuals and entities were appointed for allegedly accouterment actual abetment to the IRA in the activities declared above: o Concord Administration and Consulting LLC o Concord Catering o Yevgeniy Viktorovich Prigozhin o Dzheykhun Nasimi Ogly Aslanov o Anna Vladislavovna Bogacheva o Maria Anatolyevna Bovda o Robert Sergeyevich Bovda o Mikhail Leonidovich Burchik o Mikhail Ivanovich Bystrov o Irina Viktorovna Kaverzina o Aleksandra Yuryevna Krylova o Vadim Vladimirovich Podkopaev o Sergey Pavlovich Polozov o Gleb Igorevich Vasilchenko o Vladimir Venkov OFAC additionally appointed two entities and six individuals pursuant to Breadth 224 of CAATSA, which targets cyber actors operating on annual of the Russian government. While the FSB had ahead been appointed by the Obama Administration beneath E.O. 13694, this marks the aboriginal time OFAC has acclimated its Breadth 224 ascendancy to baptize new SDNs. Federal Aegis Service (FSB) – Russian intelligence alignment appointed for its declared assurance in cogent activities that attenuate cybersecurity on annual of the Russian government. OFAC accurately declared that FSB has activated cyber accoutrement to ambition Russian political dissidents as able-bodied as assorted US government officials. Main Intelligence Directorate (GRU) – Russian aggressive intelligence alignment additionally appointed for its declared assurance in cogent activities that attenuate cybersecurity on annual of the Russian government. OFAC accurately declared that the GRU was anon circuitous in the arrest of the 2016 US acclamation and captivation in the declared NotPetya cyber-attack which targeted the US in 2017. The afterward individuals were anecdotic for alleging acting on annual of the GRU: o Sergei Afanasyev o Vladimir Alexseyev o Sergey Gizunov o Igor Korobov o Igor Kostyukov o Grigoriy Molchanov FSB-Related Allotment for Import-Approval Activities Afterward FSB’s antecedent appellation in 2016, US exporters aloft apropos that the sanctions could baffle with their accustomed business operations back they are appropriate to accord with the FSB in its authoritative capacity. In accession to its intelligence role, the FSB regulates the acceptation of technology that contains cryptographic functions, such as corpuscle phones, tablets and printers. To abode these concerns, in February 2017 OFAC issued a accustomed allotment acceding assertive bound diplomacy with the FSB bare to accretion approval to acceptation articles into Russia. Afterwards the re-designation of FSB pursuant to CAATSA breadth 224 this year, OFAC re- issued this allotment as Cyber-Related Accustomed Allotment No. 1A (“GL 1A”). The adapted GL 1A cites the new CAATSA-related authorities but contrarily is substantively identical to the antecedent license. Indeed, OFAC appear advice allegorical that, beneath GL 1A, US bodies abide acceptable to appoint in bound diplomacy with the FSB that are bare to accretion approval to acceptation articles into Russia, including accepting licenses and certificates, advantageous fees and acknowledging with FSB administration or authoritative actions. Activities especially banned by GL 1A accommodate the accouterment of appurtenances or technology to or on annual of the FSB, importing or exporting appurtenances to the Crimea arena of Ukraine and any added diplomacy with added SDNs. Lastly, OFAC acclaimed that the new allotment does not affect the adeptness of US bodies to biking to Russia, and the sanctions do not administer to transactions, such as acknowledging with bound ascendancy requirements, that are commonly adventure to biking to and from Russia. OFAC CONFIRMS CAATSA SANCTIONS-EVADERS ALSO APPLIES TO SSI-LIST DESIGNEES Finally, on March 15, OFAC appear FAQ 546 accompanying to CAATSA. As declared above, breadth 228 of CAATSA requires the Admiral to appoint blocking sanctions (i.e., appellation on OFAC’s SDN list) on a “foreign person” that the admiral determines advisedly facilitates a cogent transaction or transactions, including ambiguous or structured transactions, for or on annual of “any actuality accountable to sanctions imposed by the United States with annual to the Russian Federation” or their actual ancestors members. OFAC’s new advice affirmed that for purposes of this section, the byword “sanctions imposed by the United States” accommodate bodies listed on either the SDN or SSI Lists, as able-bodied as bodies accountable to sanctions pursuant to OFAC’s 50 percent rule. UKRAINE-RELATED DESIGNATIONS On January 26, OFAC appointed twenty-one individuals and nine entities accompanying to activities in Ukraine that purportedly abide to attenuate the Minsk Accords. The Treasury Department declared the sanctions as affectionate of its “continued charge to advance sanctions burden on Russia until it absolutely accouterments its commitments beneath the Minsk agreements.” OFAC appointed one alone and two entities accompanying to Russia’s alteration of four turbines fabricated by a Russian-German collective adventure to Crimea—an activity which OFAC declared occurred admitting bright acknowledged accoutrement prohibiting the use of the turbines in Crimea and afresh assurances that no such alteration would booty place. Bound Accountability Aggregation Adopted Bread-and-butter Affiliation Technopromexport (Technopromexport LLC) – article declared to be amenable for the alteration of four turbines to Crimea. According to OFAC, in July 2017, four turbines bogus by a collective adventure amid PJSC Adeptness Machines and Siemens AG were alien to Crimea, “despite bright acknowledged accoutrement prohibiting the use of the turbines in Crimea.” Sergey Topor-Gilka – Accustomed Administrator of Technopromexport LLC and OAO Technopromexport, which was appointed in December 2015 pursuant to E.O. 13685 for operating in Crimea. Topor-Gilka is actuality appointed for accepting acted or declared to act for or on annual of, anon or indirectly, Technopromexport LLC and OAO Technopromexport. PJSC Adeptness Machines – Russian co-owner of the collective adventure that produced the turbines; OFAC acclaimed that its administrator has about declared his abutment for Crimean basement projects. Adeptness Machines is actuality appointed for accepting materially assisted, sponsored,or provided financial, material, abstruse or added abutment for, or appurtenances or casework to or in abutment of, OAO Technopromexport and Technopromexport LLC. The anew appointed bodies additionally included eleven individuals declared as “Ukrainian separatists,” who absorb assorted offices of the declared Donetsk People’s Republic (DPR) and the Luhansk People’s Republic (LPR) in the eastern arena of the country. The afterward individuals were appointed beneath E.O. 13660 for accepting allegedly affianced in assorted activities abrasive the peace, security, stability, ascendancy or territorial candor of Ukraine: Igor Antipov – “Minister of Information” of the declared “Donetsk People’s Republic (DPR).” Aleksey Granovsky – “Minister of Industry and Trade” of the DPR. Ekaterina Matyushchenko – “Minister of Finance” of the DPR. Natalya Nikonorova – “Minister of Adopted Affairs” of the DPR. Vladimir Pavlenko – “Minister of Accompaniment Security” of the DPR. Elena Radomskaya – “Minister of Justice” of the DPR. Aleksandr Timofeev – “Minister of Taxes and Revenues” of the DPR. Elena Kostenko – “Acting Bread-and-butter Development Minister” of the LPR Svetlana Malakhova – “Minister of Labor and Amusing Policy” of the LPR. Pavel Malgin – “Acting Minister of Fuel, Energy, and Atramentous Industry” of the LPR. Dmitry Ovsyannikov – purportedly adopted “Governor of Sevastopol” in an acclamation organized by Russia. OFAC additionally appointed three individuals and four entities beneath E.O. 13660 for declared captivation in the adulterous atramentous barter amid Ukraine’s agitator regions and Europe: ZAO Vneshtorgservis – atramentous mining activity purportedly accustomed to act on annual of the DPR and LPR. Vladimir Pashkov – accustomed administrator of ZAO Vneshtorgservis. Gaz-Alyans, OOO – exporting aggregation declared to acquire assisted, sponsored or provided financial, actual or abstruse abutment for, or appurtenances or casework to or in abutment of, ZAO Vneshtorgservis, the DPR and the LPR. Oleksandr Melnychuk – declared to acquire assisted, sponsored or provided financial, actual or abstruse abutment for, or appurtenances or casework to or in abutment of, the declared LPR, namely through the adulterous consign of coal. Doncoaltrade Sp. Z O O – exporting aggregation appointed for allegedly actuality ancient or controlled by Oleksandr Melnychuk. Serhiy Melnychuk – declared to acquire assisted, sponsored or provided financial, actual or abstruse abutment for, or appurtenances or casework to or in abutment of, the LPR. Ugolnye Tekhnologii, OOO – exporting aggregation declared to acquire assisted, sponsored or provided financial, actual or abstruse abutment for, or appurtenances or casework to or in abutment of, the LPR and DPR. Additionally, OFAC appointed four individuals and two entities beneath E.O. 13661, which authorizes sanctions adjoin Russian admiral (and others) that accommodate abutment to ahead appointed persons. The afterward admiral of the Russian Federation were listed as SDNs: Andrey Cherezov – Russian Agent Minister of Activity in the Department of Operational Ascendancy and Administration in the Electric Adeptness Industry; appointed for declared commitment of turbines to Crimea and for actuality an official of the Russian Federation. Evgeniy Grabchak – Arch of the Department for the Russian Activity Ministry’s Department of Operational Ascendancy and Administration in the Electric Adeptness Industry. He is amenable aural the Russian Ministry of Activity for the development of electro-energetic projects in Crimea. Aleksandr Pentya – Vice Admiral with ABR Management, which was appointed pursuant to E.O. 13661 in September 2016 for acting on annual of Coffer Rossiya. Pentya was appointed for acting or purporting to act for or on annual of, anon or indirectly, ABR Management. Evro Polis Ltd. – Russian aggregation that has apprenticed with the Government of Syria to assure Syrian oil fields; appointed for actuality ancient or controlled by Yevgeniy Prigozhin, who was appointed pursuant to E.O. 13661 in December 2016 for accouterment abutment to chief admiral of the Russian Federation. In backward 2017, Bogdan Kolosov, who is the Department Administrator for Customer Service at the Russian- based busline casework aggregation Instar Logistics, allegedly accommodating a accession of weapons with ahead appointed Kalashnikov Concern All-embracing Business Development Administrator Vakhtang Karamyan. Instar Logistics is actuality appointed for acting or purporting to act for or on annual of, anon or indirectly, Kalashnikov Concern. Kolosov is actuality appointed for materially assisting, allotment or accouterment financial, actual or abstruse abutment for, or appurtenances or casework to or in abutment of, Kalashnikov Concern. Finally, OFAC appointed one architecture article and two associated individuals pursuant to E.O. 13685, which authorizes sanctions adjoin bodies operating in the Crimea arena of Ukraine: VAD, AO – Russian architecture aggregation amenable for the architecture of the Tavrida Highway in Crimea. OFAC declared that VAD, AO and the declared “Republic of Crimea” active a arrangement for the highway’s architecture at a amount of $2.92 billion. Valeri Abramov – co-founder and Accustomed Administrator of VAD, AO. Viktor Perevalov – co-founder and Aboriginal Agent Accustomed Administrator of VAD, AO. Additionally on January 26, OFAC articular twelve subsidiaries that are ancient 50 percent or added by a Russian company, Surgutneftegaz, which was ahead added to OFAC’s sectoral sanctions annual (SSI List) beneath Directive 4 (pursuant to E.O. 13662). Although the subsidiaries were already accountable to the aforementioned restrictions as their ancestor article beneath the 50% rule, OFAC accurately articular the subsidiaries to accommodate added advice to abetment the clandestine breadth with sanctions compliance. IRAN On January 12, Admiral Trump afresh renewed the acting abandonment of US accessory sanctions on Iran, which are currently abeyant beneath the acceding of the Collective Comprehensive Plan of Action. Even as Admiral Trump connected the accustomed sanctions relief, he vowed to cull out of the nuclear accord if Congress and European allies do not “fix the deal’s adverse flaws,” including extending its terms, bolstering inspections and annoyance the country’s ballistic missile program. The abutting borderline for Admiral Trump to renew or abjure the abandonment of sanctions will be May 12, 2018. European media appear this division that several countries, including Germany, are lobbying EU counterparts to accede to new sanctions adjoin Iran in an advance to anticipate the United States from abrogation the JCPOA. Iran, in contrast, has pre-emptively alone any modification to the agreement. In accession to the President’s connected address adjoin the nuclear deal, the Trump Administration this division connected to sanction individuals and entities in Iran declared to be circuitous in the development of the county’s ballistic missile program, animal rights abuses and cyber-related misconduct. OFAC DESIGNATIONS On January 12, OFAC appointed fourteen individuals and entities for declared captivation in animal rights abuses and censorship activities in Iran, as able-bodied as for declared abutment of appointed Iranian weapons proliferators. The afterward designations were fabricated pursuant to E.O. 13553, which targets animal rights abuses by the Iranian government; E.O. 13606, which targets animal rights abuses by the Governments of Iran and Syria via advice technology; E.O. 13628, which authorizes sanctions for those circuitous in censorship, banned on abandon of advertisement or activities that absolute admission to book or advertisement media; and E.O. 13382, which targets proliferators of weapons of accumulation abolition and their supporters. Sadegh Amoki Larijani – appointed pursuant to E.O. 13553 for his involvement, as “head of Iran’s judiciary” in accustomed out sentences in bribery of Iran’s all-embracing obligations. The sentences allegedly included the beheading of individuals who were juveniles at the time of their crime, as able-bodied as the ache or cruel, atrocious and aspersing analysis or bribery of prisoners, including amputations. Morteza Razavi – appointed pursuant to E.O. 13382 for acting for or on annual of Green Wave Telecommunications and Fanamoj. Fanamoj was ahead appointed in October 2017 for its abutment of Iran’s Islamic Revolutionary Guard Corps (IRGC) and Iran’s Naval Aegis Missile Industry Group. Shi Yuhua (a Chinese civic and agent of Wuhan Sanjiang Acceptation and Consign Co. Ltd.) – appointed pursuant to E.O. 13382 for acting for or on annual of Wuhan Sanjiang and for accepting provided abutment of Iran’s Shiraz Electronics Industries (SEI), which is ancient by Iran’s Ministry of Aegis and Armed Forces. Both Wuhan Sanjiang and SEI are appointed entities pursuant to E.O. 13382. Yuhua, on annual of Wuhan Sanjiang, allegedly awash aeronautics accessories and specialized sensors to SEI and again attempted to beard the diplomacy to abstain detection. Zhu Yuequn ( a Chinese civic and adumbrative of Bochuang Ceramic, Inc.) – appointed pursuant to E.O. 13382 for allegedly facilitating the sale, through Bochuang Ceramic Inc., of advance zirconium titanate that was ultimately headed appear Iran’s Electronic Components Industries, a appointed entity. Gholamreza Karaj Ziaei (Director of the Rajaee Shahr Prison) – appointed for declared animal rights abuses pursuant to E.O. 13553. The Rajaee Shahr Bastille is declared to acquire denied prisoners medical affliction and admission to acknowledged representation, as able-bodied as concrete and animal abuse. The afterward entities were additionally designated: Rajaee Shahr Bastille – appointed pursuant to E.O. 13553 for perpetrating animal rights abuses, including declared concrete and animal bribery of prisoners, as able-bodied as the abnegation to prisoners of able medical affliction and admission to acknowledged representation. Islamic Revolutionary Guard Corps Electronic Warfare and Cyber Aegis Alignment – appointed pursuant to E.O. 13606 for its accord with the IRGC, which is itself appointed in the Addendum to E.O. 13606. The Supreme Council of Cyberspace – appointed pursuant to E.O. 13628 for allegedly agreeable in censorship and attached abandon of expression, including blocking assorted amusing media sites, akin admission to annual websites and websites analytical of the Iranian regime. The Civic Cyberspace Centermost (owned or controlled by the Supreme Council of Cyberspace) – appointed for allegedly preventing Iranians from accessing internet networks and attempting to anticipate Iranians from accessing Western media content. Green Wave Telecommunication – appointed pursuant to E.O. 13382 for its accord with Fanamoj, an article ahead appointed pursuant to E.O. 13382 for its abutment of the IRGC and Iran’s Naval Aegis Missile Industry Group. Iran Helicopter Abutment and Renewal Aggregation (PANHA) – appointed pursuant to E.O. 13382 for actuality ancient or controlled by Iran’s Aviation Industries Organization. PANHA, an Iranian aegis industry firm, provides aliment and added casework for Iran’s aggressive helicopters and aircraft. Iran Aircraft Industries (SAHA) – appointed pursuant to E.O. 13382 for actuality ancient or controlled by Iran’s Aviation Industries Organization. SAHA, additionally an Iranian aegis industry firm, is the better provider of check and abstruse modification casework for Iran’s aggressive and burden aircraft. Pardazan Arrangement Namad Arman (PASNA) – appointed pursuant to E.O. 13382 for its abutment of Iran’s Electronic Components Industries (ECI). ECI was itself appointed pursuant to E.O. 13382 in July 2012 for actuality ancient or controlled by Iran’s Ministry of Aegis for Armed Forces Logistics. PASNA has allegedly approved to annex advance zirconium tritanate, which is acclimated to advance aggressive weapons. Bochuang Ceramic, Inc. – appointed pursuant to E.O. 13382 for allegedly accepting provided, or attempted to provide, abutment for PASNA, including the auction of advance zirconium tritanate. On January 4, OFAC appointed bristles Iranian entities, which are ancient by the ahead appointed Shahid Bakeri Industrial Accumulation (SBIG), and which are declared to be circuitous in the analysis and assembly of basic genitalia that are analytical to Iran’s ballistic missile program. Specifically, OFAC appointed the afterward bristles subordinates of SBIG: Shahid Kharrazi Industries – declared to be amenable for the development and assembly of advice and ascendancy systems for solid-propellant ballistic missiles. Shahid Sanikhani Industries – declared to be amenable for casting and abating solid-propellant for Iran’s solid-propellant ballistic missiles. Shahid Moghaddam Industries – declared to be amenable for the development and assembly of solid-propellant missile motor cases, ballistic missile launchers, and arena abutment equipment. Shahid Eslami Analysis Centermost – allegedly serves as the analysis and development alignment aural SBIG. Shahid Shustari Industries – allegedly created for the development of cilia abstracts for SBIG. On March 23, OFAC appointed one article and ten individuals pursuant E.O. 13694, which targets the acreage of bodies affianced in awful cyber-related activities. OFAC declared that the accustomed parties “engaged in the annexation of admired bookish acreage and abstracts from hundreds of US and third-country universities and media companies for clandestine cyberbanking gain.” The afterward article and nine individuals were designated: Mabna Institute – an Iran-based aggregation that allegedly affianced in the annexation of claimed identifiers and bread-and-butter assets for clandestine cyberbanking gain. Specifically, OFAC asserted that the Mabna Institute accommodating cyber intrusions into computer systems of hundreds of universities throughout the world, including in the United States, for the purpose of accepting proprietary accurate assets for the annual of Iran’s Islamic Revolutionary Guard Corps (IRGC). Gholamreza Rafatnejad – declared founding accessory of the Mabna Institute. Ehsan Mohammadi – declared founding accessory of the Mabna Institute Seyed Ali Mirkarimi – declared hacker and Mabna Institute contractor. Mostafa Sadeghi – declared hacker and accessory of the Mabna Institute. Sajjad Tahmasebi – declared Mabna Institute contractor. Abdollah Karima – allegedly ancient and operated a aggregation that sold, through a website, admission to baseborn bookish abstracts acquired through computer intrusions. Abuzar Gohari Moqadam – assistant and declared accessory of the Mabna Institute. Roozbeh Sabahi – declared architect for the Mabna Institute. Mohammed Reza Sabahi – declared architect for Mabna Institute. OFAC accurately declared that Sabahi assisted in the accustomed out of Mabna’s extra phishing advance targeting universities. Behzad Mesri – OFAC alleges that Mesri compromised assorted user accounts acceptance to a US media and ball aggregation in adjustment to again accretion crooked admission to the company’s computer servers and abduct admired baseborn abstracts including arcane and proprietary information, cyberbanking abstracts and agent acquaintance information. Mesri is additionally the accountable of an allegation appear by the US District Cloister for the Southern District of New York on November 21, 2017. US PROSECUTORS FILE CHARGES AGAINST IRANIAN NATIONAL FOR SANCTIONS EVASIONS Accession non-US agent is adverse accuse in US federal cloister of artifice bread-and-butter sanctions adjoin Iran. Prosecutors adduce that Ali Sadr Hashemi Nejad (Sadr), administrator of Malta-based Pilatus Bank, confused $115 actor from Venezuela through the US cyberbanking arrangement as allotment of a $476 actor accord to body 7,000 apartment units in Venezuela. Sadr was arrested on March 19, 2018 and answerable with six counts of conspiracy, coffer fraud, sanctions artifice and money laundering. The accuse adduce that Sadr acclimated a web of carapace companies and coffer accounts beyond the apple to align US dollar payments from Venezuela’s state-run activity aggregation (PDVSA) to an Iran-based architecture aggregation (Stratus Group) ancient by Sadr’s family. According to prosecutors, the affirmation shows that Stratus Accumulation capital to be paid in US dollars, and Sadr structured the diplomacy so as to abstain sanctions restrictions. This case follows on the heels of the high-profile bent balloon of Turkish agent Mehmet Hakan Atilla, who was bedevilled in New York in January of this year. US authorities arrested Atilla while he was visiting the United States in 2017 and answerable him with sanctions violations, amid added charges, apropos to his role in acceptable Iran to address about $1 billion in oil and gas revenues through Turkey’s state-run coffer in bribery of US sanctions. Both prosecutions arresting a bright alertness on the allotment of US authorities to accompany bent charges, as adjoin to civilian or authoritative penalties, adjoin individuals alfresco the United States who breach sanctions regimes. NORTH KOREA This quarter, the US connected to use sanctions to burden North Korea to abandon its nuclear diplomacy and ballistic missile testing. Notably, OFAC targeted assorted Chinese aircraft and trading companies for allegedly continuing “to accommodate a buoy to North Korea to ammunition this regime’s nuclear ambitions.” For example, as declared added below, OFAC in January targeted China-based Beijing Chengxing Trading Co. Ltd. and Dandong Jinxiang Barter Co., Ltd. for allegedly exporting millions of dollars’ annual of metals and computer accessories to North Korea in bribery of US and U.N. sanctions. One ages later, the US appear its “largest North Korea-related sanctions tranche to date,” targeting assorted aircraft and trading companies in North Korea, China, Singapore, Taiwan, Hong Kong, and elsewhere, which were declared to acquire exported atramentous from North Korea or to acquire affianced in U.N.-prohibited ship-to-ship oil transfers. In accompanying guidance, OFAC warned that any “foreign cyberbanking institution” begin to acquire advisedly facilitated a cogent consign to or acceptation from North Korea, or advisedly facilitated a cogent transaction on annual of a North Korea-related blocked person, may lose the adeptness to advance a contributor annual in the United States. This admonishing follows the Treasury Department’s blacklisting aftermost year of China’s Coffer of Dangdong; US media appear that in contempo months the Administration has brash accretion sanctions to accommodate above Chinese banks that do not do added to abbreviate cyberbanking abutment for North Korea. In March, Admiral Trump appear that he accustomed an allurement to accommodated with North Korean baton Kim Jong Un to altercate de-escalating tensions amid the US and North Korea, and potentially annoyance the closing country’s nuclear weapon program. If the affair occurs, Admiral Trump will be the aboriginal sitting American admiral to accommodated with a North Korean leader. Capacity of the acme acquire yet to be announced, and, in the meantime, Admiral Trump has declared the US will abide to appoint able bread-and-butter sanctions. OFAC DESIGNATIONS On January 24, OFAC appointed nine entities, sixteen individuals, and six argosy in acknowledgment to North Korea’s afterward of weapons of accumulation abolition and for violations of U.N. Aegis Council Resolutions (UNSCRs). The sanctions targeted individuals, including individuals in China and Russia, declared to be affiliated with two North Korean entities that were ahead accustomed by the United States and the U.N. for activities that abutment North Korea’s actinic weapons program. Additionally, the sanctions targeted two Chinese trading companies that were about declared to accommodate abutment to the regime’s nuclear activities through trading activities. Appointed Assembly of Ryonbong Residing in Russia and China The afterward individuals were appointed pursuant to E.O. 13687, which authorizes sanctions adjoin those brash to be admiral of the North Korean government, or their supporters. The appointed individuals are assembly of the ahead accustomed Korea Ryonbong Accustomed Corporation. Jong Man Bok – Ryonbong adumbrative in Dandong, China. Ri Tok Jin – Ryonbong adumbrative in Ji’an, China. Ri Tok Jin allegedly relayed offers from China- based companies to North Korean accoutrements proliferators. Kim Man Chun – Ryonbong adumbrative in Linjiang, China. Kim Song – Ryonbong adumbrative in Linjiang, China. Ryang Tae Chol – Ryonbong adumbrative in Tumen, China. Kim Kyong Hak – Ryonbong adumbrative in Zhuhai, China, who was allegedly circuitous in the acquirement of chancy chemicals in mid-2016. Han Kwon U – Ryonbong adumbrative in Zhuhai, China. Kim Ho Kyu – Ryonbong adumbrative and Vice Consul of the North Korean Admiral Accustomed in Nakhodka, Russia. Pak Kwang Hun – Ryonbong adumbrative in Vladivostok, Russia. Pak Tong Sok – Ryonbong adumbrative in Abkhazia, Georgia, aforetime in Nakhodka, Russia. In August 2017, Pak Tong Sok reportedly abiding to arrange North Korean laborers to Abkhazia, a acceptable bribery of UNSCR 2371. Kim Pyong Chan – a Workers’ Party of Korea official. Appointed North Korean Coffer Respresentatives Residing in Russia and China In addition, OFAC accustomed the afterward bristles North Korean individuals residing in China and Russia pursuant to E.O. 13810 or E.O. 13687 (targeting individuals affiliated to North Korean cyberbanking networks). OFAC additionally acclaimed that the afterward individuals were bent to be “working on annual of or at the administration of a DPRK coffer or cyberbanking institution” for purposes of UNSCR 2321: Choe Song Nam – a UN- and US-designated Daesong Coffer adumbrative in Shenyang, China. As of backward 2016, Choe Song Nam reportedly captivated an annual at a Chinese bank. Ko Il Hwan – a UN- and US-designated Daesong Coffer official in Shenyang, China. Paek Jong Sam – reportedly a Kumgang Accumulation Coffer adumbrative in Shenyang, China. Paek Jong Sam operates in the North Korean cyberbanking casework industry, and reportedly is affiliated with several Chinese coffer accounts and companies. Kim Chol – the UN- and US-designated Korea United Development Coffer adumbrative in Dalian, China. As of 2016, he reportedly captivated an annual at a Chinese bank. Ri Myong Hun – reportedly the UN- and US-designated Adopted Barter Coffer adumbrative in Vladivostok, Russia. Appointed Trading Companies OFAC additionally targeted Chinese and North Korean trading companies for exporting over $68 actor annual of appurtenances to North Korea, and importing added than $19 actor annual of appurtenances from North Korea back 2013. The afterward three entities were appointed pursuant to E.O. 13810, which authorizes sanctions adjoin individuals and entities in key sectors of North Korea’s economy, bodies that barter with North Korea and aircraft and argosy that acquire catholic to North Korea: Beijing Chengxing Trading Co. Ltd. – a China-based trading aggregation appointed for reportedly diplomacy two bags of aeriform abstention metals to a accessory aggregation of Ryonbong. Dandong Jinxiang Barter Co., Ltd. – a China-based aggregation appointed for reportedly trading with Korea Tangun Trading Corporation, which is a appointed article by both the U.N. and the United States. Korea Tangun Trading Corporation, additionally accepted as Korea Kuryonggang Trading Corporation, is accessory to Second Academy of Natural Sciences, an article circuitous in North Korea’s weapons of accumulation abolition and missile programs, and which is additionally appointed by the U.N. and the United States. Dandong Jinxiang Barter Co., Ltd. is additionally appear to acquire exported over bisected a actor dollars’ annual of acclimated computers to North Korea. Hana Electronics JVC – one of North Korea’s alone electronics companies. Appointed North Korean Aircraft Companies Additionally pursuant to E.O. 13810, OFAC appointed the afterward bristles North Korean aircraft companies, and the six argosy in which the companies acquire an interest: Gooryong Aircraft Co Ltd. – the buyer and address administrator and abettor of Goo Ryong, a DPRK- flagged ship. Hwasong Aircraft Co Ltd. – the registered owner, ISM manager, and address and bartering administrator of the barge Hwa Song, a North Korea-flagged ship. Korea Kumunsan Aircraft Co. – the registered owner, address manager, and abettor of Kum Un San, a North Korea-flagged tanker. Korea Marine & Industrial Trdg. – the registered owner, ISM manager, address administrator and bartering administrator of the accustomed burden ships Un Ryul and Ever Glory, both North Korea-flagged vessels. CK All-embracing Ltd. – the registered buyer of the accustomed burden address Ul Ji Bong 6, a North Korea- flagged vessel. According to OFAC, Ul Ji Bong on-loaded atramentous at a anchorage in North Korea and delivered the atramentous to Russia. On February 23, 2018 OFAC appear the better North Korean sanctions amalgamation to date, targeting individuals, entities and argosy associated with the aircraft and trading industries in North Korea. The sanctions, allowable pursuant to E.O.s 13722 and 13810, are brash to agitate the approach allegedly active by the North Korean government to balk sanctions, with a focus on adverse the amphibian activities that facilitate atramentous and ammunition transports. In total, OFAC appointed one individual, 16 North Korean entities and 19 of their argosy and nine all-embracing aircraft entities and their vessels. Appointed North Korean Aircraft Companies Pursuant to E.O. 13810, which targets, in part, individuals and entities that are allotment of the North Korean busline industry, OFAC appointed the afterward 16 North Korean aircraft companies and their North Korean-flagged vessels: Chonmyong Aircraft Co. and its barge Chon Myong 1 Hapjanggang Aircraft Co. and its barge Nam San 8 and accustomed burden address Hap Jang Assemblage 6 Korea Achim Aircraft Co. and its barge Chon Ma San Korea Ansan Aircraft Co. and its barge An San Korea Myongdok Aircraft Co. and its barge Yu Phyong Phyongchon Aircraft and Marine and its argosy Ji Song 6, Ji Song 8 and Woory Star Paekma Aircraft Co. affliction of Aboriginal Oil JV Co. Ltd. and its barge Paek Ma Korea Samjong Aircraft Co. and its argosy Sam Jong 1 and Sam Jong 2 Korea Samma Aircraft Co. and its barge Sam Ma 2 Korea Unpha Aircraft and Trading and its barge Kum Assemblage 3 Korea Yujong Aircraft Co. Ltd. and its barge Yu Jong 2 Pochon Aircraft and Administration and its barge Po Chon Songwon Aircraft and Administration and its barge Song Won Tonghung Aircraft and Trading Co. and its barge Tong Hung 5 Myohyang Aircraft Co. and its barge Yu Son Appointed All-embracing Aircraft Companies Pursuant to E.O. 13810, OFAC additionally accustomed the afterward all-embracing aircraft companies and their vessels. According to OFAC, the argosy acquire been acclimated to consign atramentous from North Korea, or contrarily acquire affianced in ship-to-ship transfers of aesthetic petroleum articles in bribery of United Nations policies: Aboriginal Oil JV Co. Ltd. and its barge Paek Ma Hongxiang Marine Hong Kong Ltd. and its barge Oriental Treasure 9 Huaxin Aircraft HongKong Ltd. and its barge Asia Bridge M.T. Koti Corp. and its barge Koti Chang An Aircraft & Technology and its barge Hua Fu 10 Liberty Aircraft Co. Ltd. Shanghai Dongfeng Aircraft Co. Ltd. and its barge Dong Feng 6 Shen Zhong All-embracing Aircraft and its argosy Hao Fan 2 and Hao Fan 6 Weihai World-Shipping Freight and its barge Xin Guang Hai 7 Yuk Tung Activity Pte. Ltd. and its barge Yuk Tung Finally, OFAC accustomed a Taiwanese national, Yung Yuan Tsang, who is declared to acquire accommodating North Korean atramentous exports with a Russian-based North Korean broker, and is declared to acquire a history of added activity to balk sanctions. OFAC additionally accustomed to Taiwanese entities controlled by Tsang: Pro-Gain Accumulation Corporation and Kingly Won All-embracing Co., Ltd. OFAC asserted that, in 2017, Tsang and Kingly Won attempted to appoint in an oil accord admired at over $1 actor with the Russian abutting Independent Petroleum Company, which was itself appointed in 2017. OFAC GUIDANCE RELATED TO NORTH KOREA SHIPPING PRACTICES In affiliation with the February designations, OFAC issued advising advice advantaged “Sanctions Risks Accompanying to North Korea’s Aircraft Practices.” The Advising alerts bodies globally about ambiguous aircraft practices acclimated by North Korea to balk sanctions, and warns adjoin the accident of actionable the US sanctions regime. OFAC warned that North Korea generally conceals the accurate character of argosy in an accomplishment to balk sanctions, including by: (i) physically altering the vessel’s All-embracing Amphibian Alignment identification number; (ii) concealing the agent or destination of its burden by appointment the burden at sea rather than at anchorage (a ship-to-ship transfer); (iv) falsifying burden and barge documentation; and (v) by disabling or manipulating a vessel’s automated identification arrangement (AIS) to affectation the vessel’s movements. To abate adjoin the accident of actionable sanctions, OFAC encouraged bodies globally to apparatus the afterward types of measures: (i) ecology for AIS manipulation; (ii) administering analysis above-mentioned to agreeable in ship-to-ship transfers in the breadth surrounding the Korean peninsula; and (iii) reviewing all affidavit and leveraging accessible resources. VENEZUELA Venezuela this division appear the barrage of its own cryptocurrency in hopes of mitigating the aftereffect of contempo US cyberbanking sanctions. The oil-backed currency, the “petro,” will represent a butt of awkward oil from the country. Venezuelan Admiral Nicolás Maduro said in February that the absolution of the petro, which represents the aboriginal cryptocurrency clearly launched by a government, aloft $735 actor on the aboriginal day. Iran additionally appear this division that it was developing a state-backed calendar currency. The Trump Adminstration responded by arising a new controlling order, declared added below, which formally prohibits US bodies from ambidextrous in the Venezuelan petro. Meanwhile, the US connected its arrangement of anecdotic specific Venezuelan individuals for their declared roles in acknowledging anti-democratic initiatives in the Maduro regime. On January 5, OFAC appointed four added Venezuelan government admiral pursuant to Controlling Adjustment 13692. E.O. 13692, originally active in March 2015, authorizes sanctions adjoin individuals affianced in abrasive capitalism in Venezuela. According to OFAC, the afterward individuals were associated with accessible bribery and autonomous repression in Venezuela: Rodolfo Clemente Marco Torres – Governor of the Venezuelan accompaniment of Aragua and an External Administrator on the Lath of Admiral of Petróleos de Venezuela, S.A. (PdVSA). Marco Torres ahead captivated assorted government positions, and is a retired Accustomed from the Civic Bolivarian Armed Forces. According to OFAC, Marco Torres is allegedly affiliated to bribery schemes accompanying to aliment imports controlled by the Venezuelan military. Francisco Jose Rangel Gomez – aloft Governor of Bolivar Accompaniment and retired army general. Rangel Gomez is declared to be affiliated to bribery activities, such as deepening armed gangs operating in Bolivar and pressuring courts to absolution assemblage assembly that are apprehended. OFAC additionally declared that Rangel Gomez is affiliated to networks of base aggressive officials. Fabio Enrique Zavarse Pabon – Division Accustomed of the Bolivarian Civic Guard. OFAC declared that Zavarse Pabon is amenable for acts of repression by assembly of the Bolivarian Civic Guard adjoin artery protestors in Venezuela. Gerardo Jose Izquierdo Torres – Above Accustomed of the Army, Accompaniment Minister for the New Bound of Accord and the Controlling Secretary of the Presidential Bound Commission. OFAC declared that Izquierdo Torres has “used his positions to accumulation from bribery at the amount of the Venezuelan people.” On March 19, OFAC additionally appointed four accustomed or aloft Venezuelan government admiral pursuant to Controlling Adjustment 13692, which targets, amid added things, individuals circuitous in accessible corruption, anti- autonomous activities and animal rights abuses in Venezuela. The advertisement is allotment of the US Treasury Department’s “ongoing efforts to highlight the bread-and-butter bribery and ancient corruption” of the Maduro regime. The afterward individuals were designated: Willian Antonio Contreras – arch of the Superintendency for the Aegis of Socioeconomic Rights (SUNDDE), the bureau amenable for arty amount controls in Venezuela. Contreras is additionally the Vice Minister of Centralized Commerce aural the Ministry of Popular Adeptness of Abridgement and Finance. Nelson Reinaldo Lepaje Salazar – acting Arch of the Office of the Civic Treasury of Venezuela. OFAC acclaimed that the Venezuelan Civic Treasury has been the accountable of antecedent bribery allegations, as it was declared that Admiral Maduro blanket about $10 actor from the Civic Treasury. Carlos Alberto Rotondaro Cova – aloft Admiral of the Lath of Admiral of the Venezuelan Institute of Amusing Aegis (IVSS), the government bureau tasked with accouterment patients with drugs for abiding conditions. Américo Alex Mata García – appointed as an Alternate Administrator on the Lath of Admiral of the Civic Coffer of Apartment and Habitat, additionally accepted as BANAVIH, beneath the Ministry of Popular Adeptness for Habitat and Housing. NEW GUIDANCE ON VENEZUELA FINANCIAL SANCTIONS On February 12, 2018 the Department of the Treasury appear two new Venezuela-related Frequently Asked Questions (FAQs). The new FAQs accommodate added advice on debt-related prohibitions in E.O. 13808, including the acceptation of “new debt,” and the cancellation of assertive backward payments from the Government of Venezuela, including from Petroleos de Venezuela, S.A. (PdVSA). OFAC appear FAQ 553, which provides the Treasury Department’s analogue of “new debt” for purposes of E.O. 13808. The FAQ clarifies that OFAC considers “new debt” to be debt created on or afterwards August 25, 2017, and provides assorted examples of “debt,” including loans and extensions of credit. OFAC does not accede debt that was created above-mentioned to August 25, 2017 to be “new debt” so continued as the acceding of the debt apparatus (including, for example, the breadth of the claim aeon or any absorption amount applied) agreed to by the parties do not change on or afterwards August 25, 2017. Such preexisting debt does not charge to accommodate to the 30- or 90-day tenors imposed beneath E.O. 13808, and US bodies may aggregate and acquire acquittal for such debt behindhand of whether the accordant articulation of the Government of Venezuela, including PdVSA, pays during the agreed-upon acquittal period. In FAQ 554, OFAC additionally antiseptic that for “new debt” (debt created on or afterwards August 25, 2017), US bodies are not acceptable to acquire acquittal from PdVSA or added segments of the Government of Venezuela if acquittal for a debt is not accustomed aural the applicative aeon defined in E.O. 13808. In diplomacy breadth PdVSA or accession articulation of the Government of Venezuela fails to pay a debt in abounding aural 90 or 30 days, as applicable, US bodies charge access a specific allotment from OFAC afore accepting payment. However, OFAC acclaimed that “to abate abeyant abuse to US bodies who acquire not accustomed acquittal accompanying to new debt … aural the applicative ability period,” it would admission specific licenses on a case-by-case base so continued as (1) the debt is based on an acceding that complies with applicative sanctions requirements and prohibitions; (2) the debt is “new debt” created afore March 14, 2018; (3) the accordant articulation of the Government of Venezuela bootless to pay its debt aural the agreed-upon, accustomed acquittal period; and (4) the transaction is not contrarily prohibited. TRUMP SIGNS EXECUTIVE ORDER EXPLICITLY ADDRESSING NEW VENEZUELA DIGITAL CURRENCY On March 19, 2018 Admiral Trump active a new controlling order, Controlling Adjustment 13827 (“Taking Added Steps to Abode the Situation in Venezuela”), which prohibits US bodies and others accountable to US administration from agreeable in all diplomacy accompanying to, accouterment of costs for and diplomacy in, any calendar currency, calendar bread or calendar badge that was issued by, or on annual of, the Government of Venezuela afterwards January 9, 2018. E.O. 13827 accurately targets Venezuela’s addition of its state-issued cryptocurrency, the “petro.” Concurrently, OFAC appear three new Frequently Asked Questions accompanying to E.O. 13827: FAQ 527 accepted that both the “petro” and “petro-gold” are brash a “digital currency, calendar coin, or calendar token” that was issued by, for or on annual of the Government of Venezuela on or afterwards January 9, 2018. FAQ 565 antiseptic that Venezuela’s acceptable authorization currency, bolivar fuerte, is NOT brash a “digital currency, calendar coin, or calendar token” that was issued by, for or on annual of the Government of Venezuela on or afterwards January 9, 2018. FAQ 566 provided advice to individuals who may acquire alternate in the pre-sale for Venezuelan calendar currency. According to OFAC, those who alternate in the pre-sale are banned from added ambidextrous in the calendar bill unless OFAC has issued a allotment accurately acceding the activity. COUNTER-TERRORISM DESIGNATIONS On January 4, the Accompaniment Department appointed Muhammad al-Ghazali, Abukar Ali Adan and Wanas al- Faqih as Specially Appointed Global Terrorists (“SDGT”). All three individuals are associated with al-Qaida affiliates al-Qa’ida in the Arabian Peninsula (“AQAP”) and al-Qa’ida in the Islamic Maghreb (“AQIM”). Al- Ghazali is a chief accessory of AQAP who is circuitous in centralized aegis and helps alternation the group’s operatives. Ali Adan is a agent baton of al-Shabaab. Moreover, al-Faqih is an AQIM accessory who helped plan the March 18, 2015, Bardo Museum advance in Tunis, Tunisia that dead at atomic twenty people. On January 23, the Accompaniment Department appointed Khalid Batarfi as a SDGT. Batarfi is the baton of AQAP and was the top administrator for AQAP in Abyan Governate, Yemen. In April 2015, Batarfi was appear from the Central Bastille of al-Mukalla afterwards AQAP militants attacked the prison. On January 23, the Accompaniment Department appointed two declared ISIS members, Siddhartha Dhar and Abdelatif Gaini, as SDGTs. Dhar was a arch accessory Al-Muhajiroun, a now-defunct agitator organization. In backward 2014, Dhar travelled from the United Kingdom to Syria to accompany ISIS. He is believed to be the masked baton who appeared in a January 2016 video assuming the beheading of several ISIS prisoners. Gaini is a Belgian- Moroccan aborigine believed to be angry for ISIS in the Middle East. On January 25, OFAC appointed six individuals as SDGTs: four individuals were appointed for their abutment of the Taliban, and two individuals were appointed for their abutment of the Haqqani Network. The afterward individuals were designated: Abdul Samad Sani – Sani was appointed for acting on annual of the Taliban. In aboriginal 2017, Sani allegedly beatific weapons to Taliban assembly who afterwards attacked an Afghan Civic Badge patrol, killing one administrator and acid two others. Previously, Sani catholic to the Persian Gulf to access allotment and food and additionally solicited donations from Taliban sympathizers in Afghanistan and Pakistan. Abdul Qadeer Basir Abdul Baseer – Baseer was appointed for acting on annual of the Taliban. In the abatement of 2017, Baseer paid Taliban commanders tens of bags of dollars for antecedent attacks conducted in Kunar Province, Afghanistan. Previously, Baseer disbursed funds to Taliban leaders and helped accounts the Taliban’s aggressive and political activities in arctic and eastern Afghanistan. Hafiz Mohammed Popalzai – Popalzai was appointed for acknowledging the Taliban and Gul Agha Ishakzai. Popalzai has served for several years on the Taliban Accounts Commission and was amenable for the Taliban’s diplomacy in southern and western Afghanistan. Maulawi Inayatullah – Inayatullah, a Taliban aggressive diplomacy member, was appointed for acknowledging the Taliban. In backward 2016, Inayatullah led Taliban attacks adjoin Afghan and Coalition Forces in Kabul, Afghanistan, and provided cyberbanking abutment for the attack’s planners. Faqir Muhammad – Muhammad was appointed for acting on annual of the Haqqani Network. For several years, Muhammad has been a above fundraiser for the Haqqani Network. Gula Khan Hamidi – Hamidi was appointed for accouterment financial, actual and abstruse abutment to the Haqqani Network. In July 2015, Hamidi facilitated advice amid a Haqqani Arrangement official and a Haqqani Arrangement acquaintance in Syria. Hamidi alternate in affairs with Haqqani leaders in Syria and accommodating the biking of militants from Pakistan to Turkey and advanced to Syria. On January 31, the Accompaniment Department appointed Ismail Haniyeh, Harakat al-Sabireen, Liwa al Thawra and Harakat Sawa’d Misr (“HASM”) as SDGTs. Ismail Haniyeh is the baton and admiral of the Political Bureau of Hamas, which was appointed in 1997 as a Adopted Agitator Alignment (“FTO”) and in 2001 as a SDGT. Haniyeh has abutting links with Hamas’s aggressive addition and has reportedly affianced in agitator attacks adjoin Israeli citizens. Harakat al-Sabireen is an Iranian-backed agitator accumulation that operates primarily in Gaza and the West Bank. The accumulation has agitated out agitator activities targeting Israel and pursues an anti-American agenda. Liwa al-Thawra is a agitator accumulation in Egypt that has claimed albatross for the October 2016 assassination of Egyptian brigadier accustomed Adel Ragai and a 2017 bombing alfresco of a badge training centermost in Tanta, Egypt. HASM is an Egyptian agitator accumulation that has claimed albatross for a September 2017 advance on Myanmar’s admiral in Cairo and the beforehand assassination of Egyptian Civic Aegis Bureau administrator Ibrahim Azzazy. On February 2, OFAC appointed six individuals and seven entities admired to Hizballah, which itself is appointed as a FTO and a SDGT. Specifically, OFAC appointed Lebanon-based Jihad Muhammad Qansu, Ali Muhammad Qansu, Issam Ahmad Saad and Nabil Mahmoud Assaf and Iraq-based Abdul Latif Saad and Muhammad Badr-Al-Din for acting on annual of Hizballah accessory and financier Adham Tabaja and his company, Al-Inmaa Engineering and Contracting. Moreover, OFAC appointed Sierra Leone-based Dolphin Trading Aggregation Limited, Sky Barter Company, and Golden Fish Liberia LTD. and Lebanon-based Golden Fish S.A.L. for actuality ancient and controlled by Ali Muhammad Qansu. Anniversary of the six individuals and seven entities appointed beneath the February 2 adjustment are additionally accountable to accessory sanctions pursuant to the Hizballah Cyberbanking Sanctions Regulations. Afterward are capacity on the accustomed individuals. On February 7, OFAC appointed three individuals, Rahman Zeb Faqir Muhammad, Hizb Ullah Astam Khan and Dilawar Khan Nadir Khan, as SDGTs. Rahman Zeb was appointed for accouterment financial, actual and abstruse abutment to Lashkar-e Tayyiba (“LeT”), a U.N. and US-designated agitator alignment based in Pakistan. In aboriginal 2016, he was circuitous in LeT’s cyberbanking operations in Pakistan and Afghanistan. Hizb Ullah and Dilawar were appointed for acting on annual of SDGT Shaykh Aminullah. Hizb Ullah served as a cyberbanking official of a Peshwar-based madrassa that was co-founded by Shaykh Aminullah. Dilawar has acted as Shaykh Aminullah’s assistant; in that role, he facilitates funds transfers and relays letters on annual of the SDGT. On February 9, OFAC appointed three individuals and three entities as SDGTs. Afterward are capacity on the SDGTs: Abdulpatta Escalon Abubakar – Abubakar was appointed for accouterment abetment to ISIS. He has served as a key facilitator for ISIS and its arrangement in the Philippines back at atomic January 2016 and has helped alteration bags of dollars to the network. In backward September 2017, Abubakar was bedfast by Filipino authorities as he was traveling from the Gulf to the Philippines. Yunus Emre Sakarya and Profesyoneller Elektronik (“PE”) – Sakarya was appointed for accouterment abetment to ISIS. Back 2015, Sakarya has served as a key facilitator circuitous in the accretion of bearding aeriform cartage to ISIS. PE, a Turkey-based company, was appointed for actuality ancient and controlled by Sakarya and for acceptable ISIS. Mohamed Mire Ali Yusuf (“Mire Ali”), Libaan Trading and Al-Mutafaq Bartering Aggregation – Mire Ali was appointed for accouterment abetment to ISIS. Back 2016, Mire Ali provided funds to ISIS leaders and ran two businesses, Libaan Trading and Al-Mutafaq Commercial, that served as fronts for ISIS- accumbent groups in Somalia. On February 20, the Accompaniment Department appointed Ansarul Islam as a SDGT. Ansarul Islam is a Burkina Faso- based agitator accumulation that has launched abundant attacks in arctic Burkina Faso, including a December 2016 advance that dead a dozen soldiers. The accumulation has additionally launched attacks adjoin badge stations in Burkina Faso and murdered a academy administrator and accession man in Kourfayel, Burkina Faso. On February 27, the Accompaniment Department appointed three ISIS-affiliated groups—ISIS-West Africa, ISIS- Philippines and ISIS-Bangladesh—as SDGTs and as FTOs. Moreover, OFAC additionally appointed four added ISIS- affiliated groups—ISIS Somalia, Jund al-Khilafah-Tunisia, ISIS-Egypt and the Maute Group—and two ISIS- affiliated leaders—Mahad Moalim and Abu Musab al-Barnawi—as SDGTs. Afterward are capacity on the appointed organizations and individuals. ISIS-West Africa and Abu Musab al-Barnawi – In August 2016, Boko Haram apprenticed adherence to ISIS and afflicted the group’s name to ISIS-West Africa. However, in August 2016, the accumulation breach into two factions. ISIS appointed Abu Musab al-Barnawi as baton of ISIS-West Africa, and the actual band adopted its aloft name, Boko Haram. ISIS-Philippines and the Maute Accumulation – In June 2016, militants in the Philippines apprenticed adherence to ISIS and encouraged added Muslims to accompany the agitator group. The Maute Accumulation declared its adherence to ISIS in 2014 and is an basic allotment of ISIS-Philippines. It is amenable for the annoy of Marawi, Philippines, which began in May 2107, and the September Davao bazaar bombing, which dead 15 people. ISIS-Bangladesh – In August 2014, a accumulation of Bangladeshi nationals apprenticed adherence to ISIS. ISIS- Bangladesh has back accomplished abundant attacks beyond the country, including an advance on the Holey Artisan Bakery in Dhaka that dead 22 people. ISIS-Somalia and Mahad Moalim – ISIS-Somalia was formed in October 2015 and has back claimed albatross for attacks beyond the country, including a May 2017 suicide bombing at a badge checkpoint that dead bristles bodies and a February 2017 advance on a day-tripper auberge that dead four aegis guards. Mahad Moalim is the co-deputy of ISIS-Somalia and facilitates the shipments of fighters and accoutrements from Yemen to Somalia. Jund al-Khilafah-Tunisia (“JAK-T”) – JAK-T, a Tunisian organization, apprenticed adherence to ISIS baton Abu Bakr al-Baghdadi in December 2014 and has back accomplished several attacks in Tunisia. ISIS-Egypt – In May 2017, ISIS appear that ISIS-Egypt had afar from accompanying Egypt-based agitator organizations. ISIS-Egypt has claimed albatross for abundant attacks in Egypt, including a December 2016 advance on Cairo’s Coptic Christian basilica that dead 28 people. On March 8, the Accompaniment Department appointed Ahmad Iman Ali and Abdifatah Abubakar Abdi as SDGTs. Ali is a arresting al-Shabaab administrator who has served as the group’s baton in Kenya back 2012. In that role, Ali has targeted Kenyan troops in Somalia and is amenable for al-Shabaab advertising geared appear Kenyan government and civilians. He has additionally recruited on annual of al-Shabaab, targeting poor adolescence in Nairobi slums. Abdi is a doubtable accessory of al-Shabaab and is capital in affiliation with a June 2014 advance in Mpeketoni, Kenya, that dead added than 50 people. On March 22, the Accompaniment Department appointed Joe Asperman, a French national, as a SDGT. OFAC additionally appointed Katibat al-Imam al-Bukhari, an Aleppo-based entity, as a SDGT. Asperman, a chief actinic weapons able for ISIS, oversaw actinic operations assembly for ISIS in Syria and deployed actinic weapons at the battlefront. Katibat al-Imam al-Bukhari is the better Uzbek angry force in Syria and has played a cogent role in the angry in northwestern Syria. The alignment fights alongside groups including al-Nusrah Front, an al-Qa’ida accessory in Syria. OFAC TARGETS NARCOTICS TRAFFICKERS & CRIMINAL ORGANIZATIONS On January 30, OFAC appointed the Zhao Wei Transnational Bent Alignment (“Zhao Wei”) pursuant to Controlling Oder 13581, “Blocking Acreage of Transnational Bent Organizations.” Based in Laos, the Zhao Wei TCO is declared to accomplishment the greater Golden Triangle Special Bread-and-butter Zone by agreeable in biologic trafficking, animal trafficking, money laundering, bribery and wildlife trafficking. OFAC additionally appointed a arrangement of four individuals—Zhao Wei, Guiqin Su, Abbas Eberahim, and Nat Rungtawankhiri—and three entities—Kings Romans All-embracing Co., Kings Romans All-embracing Advance Co. Bound and King Romans Aggregation Limited—for materially acceptable the Zhao Wei TCO. On February 14, OFAC appointed three Colombian nationals—Javier Garcia Rojas, Ruth Garcia Rojas and Wilton Cesar Hernandez Durango—as Specially Appointed Narcotics Traffickers (SDNTs) beneath the Kingpin Act. OFAC additionally appointed four companies ancient by the three appointed individuals: Agroconstrucciones Las Palmeras S.A.S., Euromecanica, Inversora Pinzon y Garcia S. En C.S. En Liquidacion and MMAG Agricultura Global S.A.S. Two of the appointed individuals, ancestors Javier and Ruth Garcia Rojas, are the longtime ally of Jose Bayron Piedrahita Ceballos and the La Oficinia de Envigado (“La Oficina”) bent group, which was appointed beneath the Kingpin Act in June 2014. The third individual, Wilton Cesar Hernandez Durango, is a aloft Colombian law administration official who has disrupted Colombian efforts to investigate Piedrahita Ceballos. On March 6, OFAC appointed eight Mexican nationals and eight Mexican companies as SDNTs beneath the Kingpin Act; those individuals and entities are affiliated to the Ruelas Torres biologic trafficking alignment (“Ruelas Torres DTO”), a Sinaloa-based bent alignment led by Joel Efren Ruelas Avila. The appointed individuals are: Maria Monserrat Avila Rocha, Patricia Lourdes Ruelas Avila, Jose Maria Ruelas Avila, Trinidad Ruelas Avila, Raquel Rivera Guerrero and Cruz Sanchez Medrano, all ancestors assembly of Joel Efren Ruelas Avila. The OFAC activity additionally targets Mexican nationals Pedro Sanchez Medrano and Reyna Isabel Rivera Sandoval, key assembly of the Ruelas Torres DTO. The eight appointed entities, all based or registered in Sinaloa, accommodate bristles agronomical companies, Agricola Ruelas S.P.R. de R.I., Alondra Produce, S.P.R. de R.I., Comercializadora Gael 4, S.A. de C.V., Dispersora Gael, S.A. de C.V. and Felixtapia S.C. de R.L. de C.V.; two architecture companies, Constructora Joel, S.A. de C.V. and Constructora Vania, S.A. de C.V.; and one accouterment boutique, Cruzita Novedades. ABU DHABI AUSTIN BEIJING BRUSSELS DUBAI FRANKFURT HONG KONG LONDON MENLO PARK MILAN NEW YORK PARIS ROME SAN FRANCISCO SÃO PAULO SAUDI ARABIA* SHANGHAI SINGAPORE TOKYO TORONTO WASHINGTON, DC Shearman & Sterling has continued brash cyberbanking institutions and bartering businesses on the best circuitous sanctions issues. If you acquire any questions, amuse feel chargeless to acquaintance one of our ally or counsel. Authors & Contributors Philip Urofsky Danforth Newcomb Stephen Fishbein Brian Burke Christopher LaVigne Barnabas Reynolds Mark Lanpher Susanna Charlwood Accompanying Casework Sanctions, Litigation, Anti-Corruption & Adopted Base Practices Act (FCPA) © 2018 Shearman & Sterling LLP. Shearman & Sterling LLP is a bound accountability affiliation organized beneath the laws of the Accompaniment of Delaware, with an affiliated bound accountability affiliation organized for the convenance of law in the United Kingdom and Italy and an affiliated affiliation organized for the convenance of law in Hong Kong. *Dr. Sultan Almasoud & Ally in affiliation with Shearman & Sterling LLP ABU DHABI • BEIJING • BRUSSELS • DUBAI • FRANKFURT • HONG KONG • LONDON • MENLO PARK • MILAN • NEW YORK • PARIS ROME • SAN FRANCISCO • SÃO PAULO • SAUDI ARABIA* • SHANGHAI • SINGAPORE • TOKYO • TORONTO • WASHINGTON, DC Copyright © 2018 Shearman & Sterling LLP *Dr. Sultan Almasoud & Ally in affiliation with Shearman & Sterling LLP
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