Sanctions Top-5 for the week ending 24 April 2020

Here are five things that happened this week in the world of economic sanctions that I think you should know about.

Sign up here if you would like to receive these summaries by email. Click here for an index of past Sanctions Top-5 briefings.

  1. The New York Department of Financial Services (NYDFS) announced a Consent Order and USD 35 million fine against Industrial Bank of Korea (IBK) for breaches of New York State anti-money laundering (AML) regulations. The New York Attorney General and the US Attorney’s Office for the Southern District of New York simultaneously announced a Non-Prosecution Agreement and Deferred Prosecution Agreement, respectively, and a USD 51 million forfeiture, following a multi-year investigation. Among other compliance failures, IBK’s New York branch failed to detect transactions connected to a billion-dollar Iran-related fraud scheme.
  2. The US Office of Foreign Assets Control (OFAC) issued a statement encouraging companies to contact the agency if they cannot meet regulatory reporting deadlines or other requirements as a result of the COVID-19 pandemic. The statement also suggests that OFAC will keep an open mind under its Economic Sanctions Enforcement Guidelines with respect to companies that are “temporarily reallocating sanctions compliance resources” as a result of COVID-19.
  3. OFAC issued an amended Venezuela General License 8-F effectively requiring five companies, including Chevron, to wind down their activities in Venezuela. Whereas the old General License 8 allowed for the maintenance of certain operations in Venezuela, the new license only authorizes certain transactions and activities that are “ordinarily incident and necessary to the limited maintenance of essential operations, contracts, or other agreements . . . for safety or the preservation of assets in Venezuela” until 1 December 2020.
  4. The United Nations Security Council committee concerning Central African Republic (CAR) added Martin Koumtamadji, leader of the militant Front Démocratique du Peuple Centrafricain (FDPC), to the UN Sanctions List. According to the listing, Koumtamadji, who founded the FDPC in 2005, poses “a threat to the peace, stability and security of the CAR,” despite taking part in an African Union-sponsored peace agreement signed in February 2019.
  5. Citing data from Castellum.AI, The Wall Street Journal reported that Pakistan’s National Counter Terrorism Authority (NCTA) has deleted more than 3,800 names from a watch list used by local financial institutions to identify suspected terrorists. According to the article, the NCTA did not provide notice or an explanation at the time of the removals. (Click here for a copy of the full Castellum.AI report.)


It was common knowledge in the industry that the NYDFS was looking into New York branches of Korean banks, so the IBK Consent Order was not entirely unexpected. What about OFAC? Although OFAC has worked closely with state and federal banking regulators on major settlements, there’s no reason it couldn’t bring an enforcement action on its own (it has before). No word if that is the case here. As for the NYDFS, the IBK Consent Order is a reminder of the regulatory risks for non-US banks with branches in the United States. New York AML regulations in particular set high standards, as demonstrated by numerous major enforcement actions against foreign banks in recent years. Meanwhile, branches outside the United States should have controls to prevent misuse of US correspondent accounts.

Hats off to everyone who made the Global Investigations Review (GIR) list of “40 Under 40” investigations specialists! It’s an honor to be listed alongside 39 other excellent practitioners from around the world. Thanks, GIR!

Don’t miss the upcoming sanctions webinar hosted by Fintelekt and the Asian Bankers Association on 6 May 2020 at 1:30 p.m. Hong Kong time (sponsored by Accuity). I’m looking forward to joining my co-panelists Hala Bou Alwan, Surendra Thapa, and Vincent Gaudel, with moderator Shirish Pathak, to talk about recent sanctions trends and much more. (Sign up here for the webinar.)

Did I miss something? Send me a message or comment on LinkedIn.

(The views expressed are my own and do not constitute legal advice. Photo from Vladislav Reshetnyak.)




US attorney in Hong Kong specializing in economic sanctions, financial crimes. Sign up for emails: LinkedIn at:

Love podcasts or audiobooks? Learn on the go with our new app.

Recommended from Medium

Primary Concept of “Virtual Window” 关于“虚拟门窗”的初步设想

Expat Nation : Ryan Fetterly’s East African Affair (I)

Lebanon: The Land of Frequenting Farewells & Continuous Collapse

An Alarming Concern From PNP and AFP

My Conversation With Audrey Kanyesigye of Just Like My Child Foundation in Uganda.

2018: The Central America Review Of The Year

Why Fortress Europe and the European Union Can’t Coexist

France’s Obsession With Nuclear Energy

Get the Medium app

A button that says 'Download on the App Store', and if clicked it will lead you to the iOS App store
A button that says 'Get it on, Google Play', and if clicked it will lead you to the Google Play store
Nicholas Turner

Nicholas Turner

US attorney in Hong Kong specializing in economic sanctions, financial crimes. Sign up for emails: LinkedIn at:

More from Medium

New Innovation Brewing: How Beer Garage & Z-Tech brings value to AB InBev and ecosystem partners… marking life easy

Brandon’s Research on Film Documentary