Mr. Sanctions

Month: December 2025

  • OFAC Penalty Imposition om Gracetown, Inc. – simplified

    Based on the Gracetown, Inc. enforcement action (released December 4, 2025), here is the reformatted and simplified summary.

    What Happened

    Gracetown, Inc., a property management company based in New York, has been fined approximately $7.1 million for severely violating US sanctions against Russia. (Note: this is not a negotiated settlement, but a financial penalty imposed on Gracetown)

    Between 2018 and 2020, Gracetown managed luxury real estate properties in New York and Washington, D.C. for Oleg Deripaska, a high-profile Russian oligarch. The company continued this work even after the US government designated Deripaska as a sanctioned person (an “SDN”) in 2018. Most notably, Gracetown ignored a specific written warning from OFAC telling them to stop. Instead of freezing the assets, they continued to collect payments and manage the properties, helping the oligarch maintain his lifestyle and assets in the US.

    The Penalty

    The Settlement Amount: $7,139,305

    How it was calculated:

    In most sanctions cases, the final penalty is significantly lower than the legal maximum. However, in this case, OFAC determined that the penalty should be near the statutory maximum.

    OFAC decided that Gracetown’s actions were “egregious” (a remarkably bad and willful violation of the law). Because of this, and because Gracetown did not confess to the government before getting caught, they faced the severe “statutory maximum” penalty rather than a negotiated lower amount.

    To arrive at the final figure, OFAC analyzed the “General Factors.” Because the violations were deemed “egregious” and were not voluntarily disclosed, the standard reductions that many companies receive were not applied.

    Aggravating and Mitigating Factors

    Aggravating Factors (What made the penalty higher)

    • Behavior: Gracetown received a direct “Notification of Blocked Property” from OFAC explicitly warning them that Deripaska was sanctioned and that they must stop dealing with him. They ignored this notice and continued their business relationship.
      • General Factor: Willful or Reckless Violation of Law
      • Applicability: Deliberately ignoring a specific government warning constitutes a “willful” violation, which is the most serious level of culpability and leads to the harshest penalties.
    • Behavior: The company’s management had full actual knowledge that they were managing properties for Deripaska and that he was a sanctioned individual.
      • General Factor: Management Involvement
      • Applicability: Violations are treated more severely when senior management is aware of the illegal conduct and approves or directs it.
    • Behavior: Gracetown failed to report that they were holding “blocked property” (the real estate) to OFAC for over 45 months, despite legal requirements to do so within 10 days.
      • General Factor: Cooperation with OFAC (Lack thereof)
      • Applicability: Concealing information or failing to file mandatory reports is viewed as a failure to cooperate and an attempt to hide violations.
    • Behavior: The company provided economic benefits to a high-priority target of US foreign policy (a Russian oligarch linked to the Kremlin), undermining the impact of the sanctions.
      • General Factor: Harm to Sanctions Program Objectives
      • Applicability: Providing significant assets or services to key sanctioned individuals is considered to cause substantial harm to US national security interests.

    Mitigating Factors (What lowered the penalty)

    • Behavior: Gracetown had not received a penalty notice or finding of violation from OFAC in the five years preceding the date of the transactions.
      • General Factor: Sanctions History
      • Applicability: OFAC considers a company’s clean record over the previous five years as a standard mitigating factor in calculating civil penalties.
    • Behavior: Gracetown cooperated with OFAC’s investigation by entering into agreements to extend the statute of limitations (tolling agreements) and responding to requests for information.
      • General Factor: Cooperation with OFAC
      • Applicability: Demonstrating a willingness to work with the government during the investigation—even if the violation itself was not self-disclosed—is typically a factor that weighs in favor of the subject.

    Despite the existence of these two mitigating factors, they had a limited impact on the final penalty amount. Because OFAC determined that Gracetown’s conduct was egregious—specifically noting the willful decision to ignore a direct government warning (“Notification of Blocked Property”)—the agency focused primarily on the statutory maximum penalty. In cases of egregious and willful violations, standard mitigating factors like a clean history or administrative cooperation are often insufficient to significantly reduce the fine, resulting in a penalty that remains near the legal limit.

    What are the Takeaways?

    Never Ignore a Government Warning

    If OFAC sends your company a letter, notice, or subpoena regarding a specific client or risk, you must act immediately. Ignoring a direct warning is the surest way to face maximum penalties and potential criminal liability.

    Property Management is “Dealing in Blocked Property”

    Managing real estate for a sanctioned person—collecting rent, paying utilities, or performing repairs—is illegal. You are effectively providing a service that helps a sanctioned person maintain their asset.

    You Must Report “Frozen” Assets

    If you discover you are holding property (like a house, apartment, or bank account) for a sanctioned person, you cannot just “do nothing.” You must officially report that property to OFAC as “blocked” within 10 days. Failing to report is a separate, serious violation.

    Gatekeepers are Targets

    OFAC and the DOJ are aggressively targeting “gatekeepers”—lawyers, property managers, and accountants—who help oligarchs hide their wealth. You cannot claim you are “just a service provider” if you know the ultimate owner is sanctioned.

    Other Resources

    For more information on the specific sanctions programs and guidelines mentioned:

    • OFAC Sanctions Lists: The official list of blocked persons (SDN List), which includes Oleg Deripaska.
    • Ukraine-/Russia-related Sanctions Regulations: The specific laws Gracetown violated, which prohibit any dealings with designated Russian oligarchs.
    • Economic Sanctions Enforcement Guidelines: The rulebook OFAC uses to determine if a case is “egregious” and to calculate the maximum penalty.

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  • Daily Digest for Thursday, December 4, 2025

    Daily Digests are simple lists of hyperlinks to new content released by sanctions and export control regulators. When appropriate, additional posts of analysis and commentary, as well as summarizations and rephrasing of the contents will be posted separately.

    Mr. Sanctions does not attempt to comprehensively cover the worlds of sanctions and export control. Opinions expressed here are my own and do not represent that of my past current or future employers.

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  • Burning Question about Executive Order 14024

    When Executive Order 14024 was issued by President Biden after the invasion of Ukraine by Russia, I noticed that more than a few authorities seemed very much like thiose in “activity-based’ or “conduct-based” sanctions programs – like the Election Interference and Cyber programs. I had always assumed it was a way of creating a “universe” of malign Russian government actions (although, to be fair, those programs’ designations are usually populated by state actors, whether from Iran, North Korea or otherwise), rather than a universe of actors performing the same bad acts, regardless of affiliation.

    So, I asked Gemini what it could find in online chatter:

    Online sources, legal analyses, and government statements indicate the Biden administration issued Executive Order (E.O.) 14024 (“Blocking Property with Respect to Specified Harmful Foreign Activities of the Government of the Russian Federation”) instead of modifying existing activity-based programs for several strategic, legal, and administrative reasons.1

    The core distinction is that E.O. 14024 creates a status-based authority (targeting actors based on who they are or where they operate), whereas the Election Interference (E.O. 13848) and Cyber (E.O. 13694/13757) programs are conduct-based (targeting actors based on what they did).

    Here is a breakdown of the specific reasons for this choice:

    1. Lower Burden of Proof (Status vs. Conduct)

    • Activity-Based Programs: To sanction someone under the Cyber or Election Interference E.O.s, the U.S. government must typically prove that a specific individual or entity engaged in, was complicit in, or materially supported a specific “bad act” (e.g., a specific hack or election influence campaign). Attribution in these areas can be technically difficult, slow, and classified.2
    • E.O. 14024: This order authorizes sanctions against persons simply for “operating in” specific sectors of the Russian economy (e.g., technology, defense, financial services).3 This allows the government to designate targets based on their presence in a high-risk sector without needing to publicly prove their direct involvement in a specific cyberattack or election scheme. This creates a much faster and more flexible designation process.

    2. Targeting the “Ecosystem” and Supply Chain

    • Broader Reach: Existing activity-based sanctions often target the “tip of the spear”—the hackers or operatives directly carrying out attacks. E.O. 14024 was designed to target the broader ecosystem that supports them.
    • Sectoral Authority: By authorizing sanctions on the Russian technology and defense sectors, the administration could target the companies that build the tools, provide the infrastructure, and fund the intelligence services that conduct these malign activities, even if those companies didn’t launch the attacks themselves.4

    3. Consolidation and Modernization

    • Unified Framework: Prior to E.O. 14024, responding to Russian aggression required a patchwork of authorities (some for Ukraine, some for Cyber, some for Election Interference, etc.). E.O. 14024 consolidated these into a single “Russian Harmful Foreign Activities” program.
    • Comprehensive “National Emergency”: The order declares a distinct national emergency focused specifically on the totality of the Russian government’s malign behavior.5 This allows for a more holistic response where a single designation can cite multiple types of bad conduct (e.g., a target involved in both cyber espionage and election interference) under one legal roof.6

    4. “Sword of Damocles” (Flexibility for Future Escalation)7

    • Scalability: E.O. 14024 was written with built-in flexibility. It allows the Secretary of the Treasury (in consultation with the Secretary of State) to identify new sectors of the Russian economy for sanctions at any time without the President needing to sign a new Executive Order.8
    • Deterrence: This structure serves as a standing threat that the U.S. can rapidly expand sanctions to other parts of the Russian economy (e.g., energy, mining, financial services) if Russian behavior continues or escalates.9

    5. Attribution to the State

    • Political Messaging: Activity-based sanctions like E.O. 13694 are global and country-agnostic—they apply to hackers in China, Iran, or North Korea equally. By issuing a Russia-specific order, the administration sent a diplomatic signal attributing these activities directly to the Government of the Russian Federation, framing them not as isolated crimes but as state-directed policy.10

    Footnotes for Executive Order 14024 Analysis

    1. Lower Burden of Proof (Status vs. Conduct)

    • Status-Based Authority: E.O. 14024 allows for the imposition of sanctions on individuals and entities determined to “operate or have operated in the technology sector or the defense and related materiel sector of the Russian Federation economy” (Section 1(a)(i)).1 This is a “status-based” authority, meaning designation is based on the target’s position within a sector rather than specific evidence of a malicious act.^1
    • Conduct-Based Limitations: In contrast, the Cyber Sanctions program (E.O. 13694, as amended) requires the government to determine that a person is “responsible for or complicit in” specific cyber-enabled activities that harm national security.^2 Similarly, the Election Interference program (E.O. 13848) requires a determination that a person has “directly or indirectly engaged in, sponsored, concealed, or otherwise been complicit in” foreign interference in a U.S. election.^3

    2. Targeting the “Ecosystem” and Supply Chain

    • Sectoral Targeting: The Biden administration stated that E.O. 14024 was designed to target the “ecosystem” supporting Russia’s malign activities. By designating the technology and defense sectors, the order enables the Treasury to sanction companies that procure technology or manufacture components for the Russian intelligence services, even if those companies do not execute the attacks themselves.^4
    • Supply Chain Disruption: Legal analysts note that this approach moves beyond the “tip of the spear” (the hackers) to the supply chain, allowing the U.S. to degrade the Russian government’s capabilities by cutting off access to western financial markets and technology for broad swaths of the Russian economy.^5

    3. Consolidation and Modernization

    • Unified Framework: Prior to E.O. 14024, sanctions authorities were fragmented across multiple emergency declarations (e.g., Ukraine-specific E.O. 13660, Cyber E.O. 13694, Election E.O. 13848). E.O. 14024 declares a new, comprehensive national emergency with respect to “specified harmful foreign activities of the Government of the Russian Federation,” creating a single legal chassis to address election interference, cyberattacks, transnational corruption, and extraterritorial activities.^6
    • Holistic Response: This consolidation allows OFAC to cite multiple bases for a single designation, simplifying the administrative record and strengthening the legal defense of the designation if challenged in court.^7

    4. “Sword of Damocles” (Flexibility for Future Escalation)2

    • Scalability: The order grants the Secretary of the Treasury, in consultation with the Secretary of State, the authority to expand sanctions to any sector of the Russian economy without a new presidential order.^8 This was explicitly designed to provide “flexibility” and leverage, allowing the administration to ratchet up pressure by targeting additional sectors (as it later did with financial services, energy, and others following the 2022 invasion of Ukraine).^93

    5. Attribution to the State

    • State-Directed Policy: The title of the order itself—”Blocking Property with Respect to Specified Harmful Foreign Activities of the Government of the Russian Federation“—is a deliberate diplomatic signal. Unlike the country-agnostic Cyber or Election orders, this order formally attributes these behaviors (SolarWinds, 2020 election interference) to the Russian state as a matter of U.S. policy.^10

    Source References:

    ^1 Executive Order 14024, Federal Register, Vol. 86, No. 73 (April 19, 2021).

    ^2 Executive Order 13694, “Blocking the Property of Certain Persons Engaging in Significant Malicious Cyber-Enabled Activities” (April 1, 2015).4

    ^3 Executive Order 13848, “Imposing Certain Sanctions in the Event of Foreign Interference in a United States Election” (September 12, 2018).5

    ^4 White House Fact Sheet, “Imposing Costs for Harmful Foreign Activities by the Russian Government” (April 15, 2021).

    ^5 See, e.g., Miller & Chevalier, “Trade Compliance Flash: New Executive Order Expands Sanctions Risk in Russia” (April 21, 2021).6

    ^6 Id.

    ^7 Congressional Research Service, “U.S. Sanctions on Russia: Legal Authorities and Related Actions” (Updated 2024).

    ^8 Executive Order 14024, Section 1(a)(i).7

    ^9 Skadden, Arps, Slate, Meagher & Flom LLP, “US Imposes Additional Round of Sanctions on Russia” (April 22, 2021).8

    ^10 Id.

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  • OFAC’s Settlement with IPI Partners, LLC

    See the original Enforcement Release for comparison or if you want to know more.

    Based on the enforcement release regarding IPI Partners, LLC (“IPI”), here is the simplified and reformatted version.

    What Happened

    The Core Issue

    IPI Partners, LLC (“IPI”), a U.S. private equity firm, agreed to pay $11,485,352 to settle potential civil liability for violating U.S. sanctions against Russia. The issue arose because IPI continued to do business involving Suleiman Kerimov, a Russian oligarch, even after he was placed on the sanctions list (the “SDN List”).

    Description of the Conduct

    In 2017 and 2018, IPI sought and accepted investment funds from Kerimov through a series of legal entities (specifically a fund called “Definition” and a trust called “Heritage Trust”).

    • The Red Flag: On April 6, 2018, OFAC designated Kerimov as a sanctioned person. This meant U.S. companies were generally prohibited from dealing with his property or interests.
    • The Legal Advice: IPI checked with outside lawyers. The lawyers reviewed the corporate structure and concluded that because Kerimov did not formally own 50% or more of the direct investment entity (“Definition”), IPI did not need to block the account.
    • The Mistake: This advice was too narrow. While Kerimov might not have met the “50% ownership” threshold for automatic blocking of the entity itself, he still held a “property interest” in the funds (as the source of funds and beneficiary). U.S. law prohibits dealing with any property interest of a blocked person, not just entities they majority-own.
    • The Violation: Relying on that advice, IPI continued to manage the investment. Between July 2018 and June 2022, IPI processed 51 transactions (such as calling for capital or distributing profits) involving these funds.

    The Penalty

    Settlement Amount

    IPI agreed to pay $11,485,352. The maximum possible base penalty for these violations was $14,356,690.

    Why this Amount? (The Rationale)

    The settlement reflects OFAC’s determination that the violations were non-egregious (meaning they were not the most serious type of willful violation) but were not voluntarily self-disclosed (IPI did not report the issue to OFAC before being investigated).

    Factors Influencing the Penalty

    OFAC considered several “General Factors” from its Enforcement Guidelines to determine the final penalty amount:

    • Aggravating Factors (Reasons the penalty could be higher):
      • IPI knew or had reason to know of the sanctioned person’s involvement. IPI was aware that Kerimov was the ultimate source of the funds but failed to exercise due caution, relying on legal advice that focused only on ownership percentages rather than the broader “interest in property.”
        • Applicable General Factor: General Factor B: Awareness of Conduct
      • The conduct harmed the sanctions program. By continuing to process transactions for a sanctioned oligarch, IPI allowed economic resources to flow to a blocked person, undermining the purpose of the Russia sanctions program.
        • Applicable General Factor: General Factor C: Harm to Sanctions Program Objectives
      • IPI is a sophisticated financial institution. IPI is a large, commercially sophisticated firm with a global presence and access to significant legal and compliance resources. OFAC holds such institutions to a higher standard of compliance.
        • Applicable General Factor: General Factor D: Individual Characteristics
    • Mitigating Factors (Reasons the penalty was reduced):
      • No recent violations. IPI had not received a penalty notice or finding of violation from OFAC in the five years preceding these transactions.
        • Applicable General Factor: General Factor E: Compliance Program (often cited regarding clean history) / General Factor I: Other Enforcement Actions
      • Substantial cooperation. After initially providing unsatisfactory responses, IPI hired new counsel, significantly improved its cooperation, and even waived attorney-client privilege to allow OFAC to review the legal advice it had received.
        • Applicable General Factor: General Factor G: Cooperation with OFAC
      • Remedial measures. IPI took steps to fix the issue and improve its compliance program to prevent future violations.
        • Applicable General Factor: General Factor F: Remedial Response

    What are the Takeaways?

    Key Lessons for the Industry

    • Look Beyond the “50% Rule”: Dealing with a sanctioned person involves more than just checking if they own 50% of a company. You must ensure you are not dealing with any “interest” of a blocked person, including indirect interests through trusts or as a beneficiary.
    • Private Equity Risks: Investment firms must thoroughly understand the ownership structure of their investors (“Limited Partners”). If a sanctioned person is behind the money, you cannot process transactions for them, even through intermediaries.
    • Legal Advice Limitations: Relying on legal advice is not a “get out of jail free” card, especially if that advice is based on an incomplete understanding of the facts or a misinterpretation of the broad scope of sanctions laws (like “interest in property”).
    • Know Your Customer (KYC): It is critical to obtain and review full diligence materials to identify the ultimate beneficial owners of investment vehicles.

    Other resources

    Reporting Suspicious Activity

    If you have information about sanctions violations, you may be eligible for a monetary award. The Financial Crimes Enforcement Network (FinCEN) maintains a Whistleblower Program that rewards individuals who provide original information leading to successful enforcement actions. You can submit tips directly to FinCEN or through OFAC.

    Contacting OFAC

    For more information on sanctions programs, specific guidance, or to join the mailing list for updates, you can contact the Office of Foreign Assets Control directly via their compliance hotline or compliance email, or by visiting the official Treasury website.

    How do you like this revamped format? I will tell you, this took more tweaking than some of the other posts I’ve done so far – Gemini originally left off the 3rd Aggravating Factor from its analysis (weird, huh?), and I had some formatting issues that I fixed by being explicit in the prompt. And then I had to wrestle it to remove external links it added…

    If there are things from the actual Enforcement Release you think should have been in this reimagined format – or if you see something it got wrong – please let me know. Thanks!

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  • FCDO’s Syria guidance for businesses and NGOs, simplified

    Go read the guidance document for all the links and detail if you want to know more…

    Background

    Interest from UK businesses in operating within Syria has grown recently, prompting the UK government to clarify the legal and policy landscape. The government supports UK businesses investing and trading in Syria, provided they follow UK laws and the activity is actually destined for Syria. However, businesses must assess their own risks, particularly regarding bad actors who might try to exploit the situation or use deceptive tactics to bypass rules.

    The political situation in Syria has shifted significantly. Following the fall of the Assad regime in December 2024, the UK government removed many sanctions in April 2025 to aid recovery. Further steps toward normalization occurred in late 2025: the UK removed Hay’at Tahrir Al-Sham (HTS) from its list of banned terrorist organizations in October, and in November, the UK removed the Syrian President and Interior Minister from the specific ISIL/Al-Qaida sanctions list. While Syria remains a high-risk environment, the new government is working toward stability, and there are potential commercial opportunities in this lower middle-income market.

    What has (and hasn’t) changed

    Significant changes to the UK’s Syria sanctions rules took effect on April 24, 2025. To help the Syrian people rebuild, the UK lifted bans on trade, finance, aviation, and energy production. Financial freezes were also removed from entities previously controlled by the Assad regime, such as the Central Bank of Syria, government ministries, and energy or media companies. The current Government of Syria itself is not subject to sanctions.

    Despite these relaxations, strict prohibitions remain in place to hold specific individuals accountable. You still cannot do business with people or entities subject to asset freezes. There are also continued bans on exporting chemical and biological weapons technology, goods used for internal repression or spying, and military equipment. Specific trade restrictions apply to the “Governing Authority of Syria”—which includes the transitional authorities and the Central Bank—regarding gold, precious metals, and diamonds. Luxury goods also cannot be sent to Syria. If you are a specific type of regulated firm, you have a legal duty to report suspected sanctions breaches.

    UN counter-terrorism sanctions

    Separate from the UK’s own rules, the United Nations maintains a counter-terrorism sanctions list (the ISIL/Al-Qaida regime) that still affects business in Syria. While the UK has removed the Syrian President and Interior Minister from its version of this list, other individuals and groups remain designated. Notably, while the UK has de-listed HTS domestically, HTS remains on the UN sanctions list.

    The Government of Syria is not on this UN list, meaning interactions with the government generally do not violate these sanctions. However, strict asset freezes and bans on military goods apply to anyone who is on the UN list. This prohibits providing funds or economic resources to them directly or indirectly. Limited exceptions exist, primarily to allow for the payment of basic expenses, but these usually require a licence.

    Relevant UK counter-terrorism laws

    Under UK law, the Terrorism Act 2000 defines which organizations are “proscribed” (banned). As of October 2025, HTS is no longer a proscribed organization, meaning membership or support for it is no longer a criminal offense in the UK. However, the group Da’esh (ISIL/ISIS) remains banned and poses a threat.

    The government aims to ensure that counter-terrorism laws do not stop legitimate humanitarian work. The Crown Prosecution Service (CPS) has guidance stating that prosecuting genuine aid organizations is generally not in the public interest. Additionally, the law offers specific protections: there is a legal defense for “genuinely benign” meetings with banned groups (such as for delivering aid), and organizations can apply to the National Crime Agency for a defense against potential terrorist financing charges for specific transactions.

    Humanitarian exceptions and exemptions

    Petroleum exceptions

    The regulations include a specific rule allowing the use of funds to purchase or supply petroleum products for humanitarian purposes. Since the general ban on petroleum trade was lifted in April 2025, this rule now primarily protects aid organizations if they need to deal with frozen assets to get fuel. If an organization relied on this rule for activities before April 2025, they must notify the government by the end of the year. For activities after April 2025, notification is only needed if the activity would otherwise breach an asset freeze.

    General licence

    In February 2025, a “General Licence” was issued to facilitate aid. This allows eligible aid organizations (and the banks that serve them) to carry out activities necessary for humanitarian assistance and basic human needs without violating asset freezes. This licence applies to the UK’s independent sanctions but not to the UN sanctions, which have their own separate humanitarian exemption.

    Related guidance documents

    Businesses and organizations should consult the specific statutory guidance for both the Syria and ISIL/Al-Qaida sanctions regimes to understand the full technical details of prohibitions and licences. A “sanctions hub” on the government website creates a central place to search for all relevant policies.

    In addition to sanctions and terrorism laws, other legal frameworks still apply. You must comply with export controls for military and dual-use goods, anti-money laundering regulations, and laws against bribery and corruption. If you are unsure whether your planned activities might break the law—especially given the complexity of the different legal regimes—you should seek independent legal advice.

    So, what do you think of this summary? Is it “enough” for you, or are you better served by the guidance document, for a first read?

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  • Today’s OFAC Designations – reformatted and enhanced

    SPECIALLY DESIGNATED NATIONALS LIST UPDATE

    Original release from OFAC

    The following individuals have been added to OFAC’s SDN List:

    [SDGT] [TCO]

    • [SDGT] Global Terrorism Sanctions Regulations: 31 C.F.R. part 594
    • [TCO] Transnational Criminal Organizations Sanctions Regulations: 31 C.F.R. part 590; Executive Order 13581

    APONTE CORDOVA, Noe Manases

    • Aliases: “El Noe”
    • Country: Venezuela
    • DOB: 30 May 1988
    • POB: Venezuela
    • Nationality: Venezuela
    • Citizen: Venezuela
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • ID: Cedula No. 19554865 (Venezuela)
    • Type: Individual
    • Linked To: TREN DE ARAGUA

    Supplemental Information:

    According to the U.S. Treasury, Aponte Cordova is a cell leader or lieutenant within the Tren de Aragua (TdA) criminal organization, operating out of Venezuela. He was designated for acting for or on behalf of TdA.

    ARAYA NAVARRO, Jimena Romina

    • Aliases: “ARAYA, Jimena”; “Rosita”
    • Countries: Venezuela; Colombia
    • DOB: 05 Sep 1983
    • Nationality: Venezuela
    • Gender: Female
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • ID: Cedula No. 16011070 (Venezuela)
    • Type: Individual
    • Linked To: TREN DE ARAGUA

    Supplemental Information:

    Jimena Araya, widely known by her stage name “Rosita,” is a prominent Venezuelan actress, model, and DJ. She gained initial fame for her role as “Rosita” in the Venevisión comedy show A que te ríes. Public records and news reports indicate she has a long-standing association with TdA leadership; she was arrested in Venezuela in 2012 for allegedly facilitating the prison escape of TdA leader Hector Rusthenford Guerrero Flores (“Niño Guerrero”) from the Tocorón penitentiary, though she was later released on bail.

    The Treasury Department identifies her as a key affiliate in the entertainment industry who provides material support to TdA. She reportedly uses her profession as a traveling DJ to move funds to the gang’s leadership, with a portion of her performance revenue being remitted to TdA. She is also the president of the designated entity Global Import Solutions S.A. and has been romantically linked to Niño Guerrero.

    ESCOBAR CABRERA, Asdrubal Rafael

    • Aliases: “El Asdrubal”
    • Country: Venezuela
    • DOB: 04 Aug 1992
    • POB: Venezuela
    • Nationality: Venezuela
    • Citizen: Venezuela
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • ID: Cedula No. 21269516 (Venezuela)
    • Type: Individual
    • Linked To: TREN DE ARAGUA

    Supplemental Information:

    Escobar Cabrera is identified by the Treasury as a cell leader or lieutenant for Tren de Aragua, operating within Venezuela. He was designated for his role in acting for or on behalf of the organization.

    ESPINAL QUINTERO, Richard Jose

    • Aliases: ESPINEL QUINTERO, Richard Jose; “El Coty”
    • Country: Venezuela
    • DOB: 19 Apr 1996
    • POB: Venezuela
    • Nationality: Venezuela
    • Citizen: Venezuela
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • ID: Cedula No. 24419648 (Venezuela)
    • Type: Individual
    • Linked To: TREN DE ARAGUA

    Supplemental Information:

    Like his associates Aponte Cordova and Escobar Cabrera, Espinal Quintero serves as a cell leader or lieutenant for Tren de Aragua in Venezuela and was designated for acting on behalf of the criminal group.

    GUERRERO PALMA, Cheison Royer

    • Aliases: “Arabe Negro”; “Mexicali”
    • Country: Chile
    • DOB: 16 Feb 1985
    • POB: Maracay, Aragua, Venezuela
    • Nationality: Venezuela
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • ID: Cedula No. 17984659 (Venezuela)
    • Type: Individual
    • Linked To: TREN DE ARAGUA

    Supplemental Information:

    Cheison Royer Guerrero Palma is the half-brother of the notorious Tren de Aragua leader, Hector Rusthenford Guerrero Flores (“Niño Guerrero”). According to the Treasury Department, he has been directly involved in the organization’s expansion efforts into Chile.

    LANDAETA HERNANDEZ, Eryk Manuel

    • Aliases: “Eryk”
    • Country: Colombia
    • DOB: 29 Aug 1982
    • Nationality: Venezuela
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • ID: Cedula No. 15978329 (Venezuela)
    • Type: Individual
    • Linked To: TREN DE ARAGUA

    Supplemental Information:

    Eryk Landaeta Hernandez is described as the former financial and logistics chief for Tren de Aragua in Bogota, Colombia, until his reported arrest by Colombian authorities in October 2024. He previously served as the bodyguard and manager for Jimena Araya (“Rosita”).

    Treasury reports state that he used his companies, Eryk Producciones SAS and Maiquetia VIP Bar Restaurant, to organize events that facilitated narcotics sales and money laundering for TdA leaders, including Niño Guerrero and Giovanni Vicente Mosquera Serrano.

    SEVILLA ARTEAGA, Kenffersso Jhosue

    • Aliases: MARTINEZ LOPEZ, Jose Daniel; SEVILLA ARTEGA, Kenffersso Jhosue; SEVILLA ATEAGA, Kenferson; “El Flipper”; “Flypper”
    • Country: Colombia
    • DOB: 29 Apr 1993
    • POB: Venezuela
    • Nationality: Venezuela
    • Citizen: Venezuela
    • Gender: Male
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • ID: Cedula No. 21098983 (Venezuela); alt. Cedula No. 1047240759 (Colombia)
    • Type: Individual
    • Linked To: TREN DE ARAGUA

    Supplemental Information:

    Known as “El Flipper,” Sevilla Arteaga was considered the “right-hand man” of TdA leader Niño Guerrero until his arrest in Cucuta, Colombia, in November 2025.

    He served as a financial leader for the gang, orchestrating extortions, kidnappings, and homicides. He managed shell businesses and illegal rent schemes across multiple countries, including Venezuela, Peru, Ecuador, Chile, Mexico, and the United States. He utilized the alias “Jose Daniel Martinez Lopez” to operate the Colombian entity Yakera y Lane SAS.

    The following entities have been added to OFAC’s SDN List:

    [SDGT] [TCO]

    • [SDGT] Global Terrorism Sanctions Regulations: 31 C.F.R. part 594
    • [TCO] Transnational Criminal Organizations Sanctions Regulations: 31 C.F.R. part 590; Executive Order 13581

    ERYK PRODUCCIONES SAS

    • Address: Bogota, Colombia
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 23 Jun 2023
    • Organization Type: Creative, arts and entertainment activities
    • ID: NIT # 901726321-4 (Colombia)
    • Linked To: LANDAETA HERNANDEZ, Eryk Manuel

    Supplemental Information:

    This company is owned and controlled by Eryk Manuel Landaeta Hernandez. According to the Treasury, it was used to organize entertainment events which served as venues for TdA’s narcotics sales and money laundering operations.

    GLOBAL IMPORT SOLUTIONS S.A.

    • Address: Anaco, Anzoategui, Venezuela
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 20 Jul 2021
    • ID: Tax ID No. J411408778 (Venezuela)
    • Linked To: ARAYA NAVARRO, Jimena Romina

    Supplemental Information:

    This Venezuela-based company is owned and presided over by Jimena Araya (“Rosita”). It was designated for acting for or on her behalf.

    MAIQUETIA VIP BAR RESTAURANT

    • Aliases: MAIQUETIA VIP; “DISCOTECA MAIQUETIA VIP”
    • Address: Cl. 17 Sur #16-54, Bogota, Colombia
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 17 Dec 2020
    • Organization Type: Beverage serving activities
    • ID: Matricula Mercantil No 3319256 (Colombia)
    • Linked To: LANDAETA HERNANDEZ, Eryk Manuel

    Supplemental Information:

    Owned by Eryk Manuel Landaeta Hernandez, this Bogota nightclub was a known performance venue for Jimena Araya (“Rosita”). Treasury investigations reveal the venue was used to sell drugs on behalf of TdA, with proceeds subsequently laundered for the gang’s leadership.

    YAKERA Y LANE SAS

    • Aliases: YAKERA YLANE S.A.S.
    • Address: Cucuta, Norte de Santander, Colombia
    • Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886
    • Organization Established Date: 20 Jun 2019
    • Organization Type: Wholesale and retail trade
    • ID: NIT # 901296366-9 (Colombia)
    • Linked To: SEVILLA ARTEAGA, Kenffersso Jhosue

    Supplemental Information: This Colombian entity is involved in wholesale and retail trade and is owned by Kenffersso Jhosue Sevilla Arteaga (“El Flipper”), who operated it under his alias “Jose Daniel Martinez Lopez.”

    So, what do you think of this way of reformatting the OFAC release and adding in info from elsewhere (I included info from the press release, and tried to find other online information)? Just a first cut… if I can find better ways of presenting this, I am certainly open to that.

    —

  • Daily Digest for Wednesday, December 3, 2025

    Daily Digests are simple lists of hyperlinks to new content released by sanctions and export control regulators. When appropriate, additional posts of analysis and commentary, as well as summarizations and rephrasing of the contents will be posted separately.

    Mr. Sanctions does not attempt to comprehensively cover the worlds of sanctions and export control. Opinions expressed here are my own and do not represent that of my past current or future employers.

    —

    , ,

  • Backgrounder: UK removes Syria sanctions in April 2025

    The following is a summarized version of the original press release from the Foreign, Commonwealth & Development Office (FCDO):

    The UK government changed Syria sanctions to help the country rebuild following the fall of the Assad regime.

    Here is a simple breakdown of what happened and why:

    What changed?

    • Easing Restrictions: The UK removed bans on key industries like bankingand energy production. This was done to encourage investment and help get Syria’s infrastructure working again.
    • Lifting Sanctions: Specific sanctions have been dropped against 12 major entities, including the Syrian Ministry of Defence, the Ministry of Interior, and various media companies. This followed the earlier unfreezing of assets for the Central Bank of Syria and the national airline.

    Why did they do this?

    • To Help Rebuild: The main goal is to let money flow back into the country so the Syrian people can repair their economy and infrastructure after years of conflict.
    • To Support Stability: The UK believes a stable Syria is safer for the region and for the UK itself.

    What is staying the same?

    • Punishing the Old Regime: Sanctions remain in place against individuals from the former Assad regime and those involved in the illegal drug trade (specifically the synthetic stimulant captagon).
    • Accountability: The new rules still allow the UK to punish human rights violations committed by Assad and his associates.

    Additional Support

    • The UK pledged £160 million in 2025 to help with Syria’s recovery and humanitarian needs.

    —

    ,

  • Daily Digest for Tuesday, December 2, 2025 (the first of many!)

    Two things hit my inbox today:

    • Supporting Syria’s future: guidance for businesses and NGOs (Guidance from FCDO)
    • Settlement Agreement between the U.S. Department of the Treasury’s Office of Foreign Assets Control and IPI Partners, LLC (OFAC Enforcement Action)

    Daily Digests are simple lists of hyperlinks to new content released by sanctions and export control regulators. When appropriate, additional posts of analysis and commentary, as well as summarizations and rephrasing of the contents will be posted separately.

    Mr. Sanctions does not attempt to comprehensively cover the worlds of sanctions and export control. Opinions expressed here are my own and do not represent that of my past current or future employers.

    —