Sanctions Top-5 for the week ending 24 April 2020

  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.)




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Nicholas Turner

Nicholas Turner

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