The OverRuled: Sanctions Module has been updated with the following actions:
- 06 Nov 2023 - daVinci Payments - USD $206,213
Between November 15, 2017 and July 27, 2022, daVinci Payments enabled reward cards to be redeemed from persons apparently resident in Crimea, Iran, Syria, and Cuba.
The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 06 Nov 2023 (BIS):
The Department of Commerce’s Bureau of Industry and Security (“BIS”) and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a joint notice highlighting a new Suspicious Activity Report (“SAR”) key term “FIN-2023-GLOBALEXPORT” for financial institutions to reference when reporting potential efforts by individuals or entities to evade U.S. export controls not related to Russia’s invasion of Ukraine. Financial institutions should continue to use the key term “FIN-2022-RUSSIABIS” when filing SARs related to suspected Russian export control evasion.
- 03 Nov 2023 (OFAC):
OFAC designated Russian national Ekaterina Zhdanova pursuant to E.O. 14024 for operating or having operated in the financial services sector of the Russian Federation economy. According to OFAC, Zhdanova has laundered money on behalf of Russian elites and ransomware actors utilizing virtual currency exchanges, including a Russian cryptocurrency exchange designated by OFAC in 2022, to evade U.S. and international sanctions and aid cybercriminals.
- 01 Nov 2023 (BIS):
The Department of Justice (“DOJ”) announced charges against Nikita Arkhipov, Nikolay Grigorev and Artem Oloviannikov of conspiracy and other charges related to a scheme to evade U.S. sanctions and export controls by shipping U.S. technology to Russian entities affiliated with the Russian military. Grigorev has been arrested but Arkhipov and Oloviannikov remain at large.
- 26 Oct 2023 (Australia):
Content provided in collaboration with Moulis Legal.
The Australian Government implemented a prohibition on supplying, selling and transferring "machinery and related goods" to Russia and specified regions of Ukraine.
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