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The Treasury Department's Office of Foreign Assets Control (OFAC) has posted a notice reminding holders of property blocked pursuant to OFAC sanctions regulations published in Chapter V of Title 31 of the Code of Federal Regulations (C.F.R.) of the requirement to provide OFAC with an Annual Report of Blocked Property (ARBP). Persons subject to this reporting requirement must submit a comprehensive report, as outlined in 31 C.F.R. § 501.603 of the Reporting, Procedures and Penalties Regulations (RPPR), of all blocked property held as of June 30 of the current year by September 30.

The annual reports must be filed using the mandatory spreadsheet form TD-F 90-22.50. Completed forms should be sent to ofacreport@treasury.gov or filed through the OFAC Reporting System (ORS). Failure to submit a required ARBP by September 30 constitutes a violation of the RPPR.

On Thursday, OFAC announced a $9,618,477 settlement with 3M Company. 3M had agreed to settle its potential liability for 54 apparent violations of OFAC's sanctions on Iran arising from its subsidiary's sale of reflective license plate sheeting to an Iranian entity controlled by Iranian law enforcement forces.

OFAC's announcement also reported a settlement with Emigrant Bank, located in New York. Emigrant agreed to remit $31,867.90 to settle its potential civil liability for apparent violations of sanctions against Iran. For approximately 26 years, Emigrant maintained a Certificate of Deposit account on behalf of two individuals ordinarily resident and located in Iran, for which it processed 30 transactions between June 2017 and March 2021 totaling $91,051.13. Emigrant had actual knowledge of the Iranian address and apparent location of the accountholders during this period.

For more information on each of these settlements, see OFAC settles with 3M Company and Emigrant Bank, in the BankersOnline OFAC Updates pages. Additional details on the Emigrant Bank settlement can be found in Emigrant Bank settles with OFAC for apparent violations in BOL's Penalty pages.

The U.S. Treasury Department has announced that OFAC has sanctioned seven individuals and four entities based in Iran, the People’s Republic of China (PRC), Russia, and Türkiye in connection with Iran’s unmanned aerial vehicle (UAV) and military aircraft development. This network has facilitated shipments and financial transactions in support of the U.S.-designated Iran Aircraft Manufacturing Industrial Company’s (HESA’s) UAV and military aircraft production, procurement, and maintenance activities. OFAC also updated HESA’s entry on the Specially Designated Nationals and Blocked Persons (SDN) List to include its new alias (Shahin Co.), which it has used to evade sanctions and export control measures.

For the names and identification information of the designated individuals and entities and the update to HESA's entry, see the September 19, 2023, BankersOnline OFAC Update.

On Monday, the Treasury Department's Office of Foreign Assets Control (OFAC) designated Mahmoud Ahmadinejad, the former president of Iran, for having provided material support to the Iranian Ministry of Intelligence and Security (MOIS), an entity concurrently designated by the Department of State. These actions are being taken pursuant to Executive Order (E.O.) 14078, “Bolstering Efforts to Bring Hostages and Wrongfully Detained U.S. Nationals Home,” which expands the tools available to deter and impose tangible consequences on those responsible for, or complicit in, hostage-taking or the wrongful detention of a United States national abroad.

The State Department designated MOIS for being responsible for, or complicit in, to have directly or indirectly engaged in, or to be responsible for ordering, controlling, or otherwise directing, the hostage-taking of a U.S. national or the wrongful detention of a U.S. national abroad.

For identification information on Ahmadinejad and the MOIS, see the September 18, 2023, BankersOnline OFAC Update.

FinCEN has announced it has published a Small Entity Compliance Guide to assist the small business community in complying with the beneficial ownership information (BOI) reporting rule. Starting in 2024, many entities created in or registered to do business in the United States will be required to report information about their beneficial owners—the individuals who ultimately own or control a company—to FinCEN. The Guide is intended to help businesses determine if they are required to report their beneficial ownership information to FinCEN.

The guide is now available on FinCEN's Beneficial Ownership Information Reporting webpage.

FinCEN has also updated its Beneficial Ownership Information Reporting FAQs, which now incorporate content from the Guide. Each updated or new FAQ is dated September 18, 2023.

Learn more about the Small Entity Compliance Guide and the updated FAQs in BOL Learning Connect's October 27, 2023, Live Webinar—Beneficial Ownership: What Your Customer Needs to Know and Do—to be presented by Deborah Crawford. REGISTER NOW!

FinCEN on Friday announced it has assessed a $15 million civil money penalty against Bancrédito International Bank and Trust Corporation (Bancrédito) for willful violations of the Bank Secrecy Act (BSA) and its implementing regulations. This is FinCEN’s first enforcement action against a Puerto Rican International Banking Entity (IBE), and includes the first violation for failure to implement and maintain an Anti-Money Laundering (AML) program under 31 C.F.R. 1020.210(b) (effective on March 15, 2021), also known as the “Gap Rule.”

“Bancrédito processed millions of dollars in suspicious transactions through the United States on behalf of high-risk customers, providing correspondent accounts to foreign financial institutions without the required due diligence and reporting required by the BSA,” said FinCEN’s Director Andrea Gacki. “With today’s action, FinCEN is sending the message that the era of easy money laundering through Puerto Rican IBEs is over.”

Bancrédito admitted to willfully violating the BSA between October 2015 and May 2022, by failing to timely report suspicious transactions to FinCEN; failing to establish a due diligence program for correspondent accounts established, maintained, administered, or managed in the United States for foreign financial institutions; and failing to implement and maintain an AML program.

News reports indicate that Bancrédito Holding Corporation, the sole shareholder of the bank, has threatened to take legal action against the Financial Crimes Enforcement Network (FinCEN) after they imposed a $15 million fine against the bank for violations of the Bank Secrecy Act (BSA) and applicable anti-money laundering regulations. According to the holding company, FinCEN had assumed an inadequate process, so the decision against it was not well-founded.

For further information on the FinCEN action, see Puerto Rican IBE pays $15M for willful BSA violations, in the BankersOnline Penalties pages.

On Friday, the Treasury Department announced that OFAC had designated 29 individuals and entities in connection with the Iranian regime’s violent suppression of nationwide protests following the death of Mahsa “Zhina” Amini in custody of its ‘Morality Police,’ and the regime’s continued efforts to detain dissenting voices and restrict access to a free and open internet.

OFAC’s action targets: 18 key members of the regime’s security forces, the Islamic Revolutionary Guard Corps (IRGC) and the Law Enforcement Forces (LEF); the head of Iran’s Prisons Organization; three individuals and one company in connection with the regime’s systematic censorship and blocking of access to the internet; and three IRGC and regime-controlled media outlets––Fars News, Tasnim News and Press TV––and three senior officials. Friday’s action was taken in coordination with partners from the United Kingdom, Canada, Australia, and other partners who are also imposing sanctions on those involved in the Iranian regime’s repression.

For the names and identification information of the designated parties, see the September 15, 2023, BankersOnline OFAC Update.

The Treasury Department on Thursday announced OFAC has imposed nearly 100 sanctions on Russian elites and Russia’s industrial base, financial institutions, and technology suppliers as the United States continues to leverage sanctions and economic restrictions to undermine Russia’s capacity to wage its war against Ukraine. The Department of State also designated more than 70 persons. Yesterday’s sanctions focus on persons benefiting from, supporting, and sustaining Russia’s war against Ukraine.

For the names and identification information of the designated parties, see the September 14, 2023, BankersOnline OFAC Update.

The Treasury Department has reported that its Office of Foreign Assets Control (OFAC), in coordination with the Drug Enforcement Administration, has designated key Hizballah operatives and financial facilitators in South America and Lebanon.

For the names and identification information of the designated parties, see the September 12, 2023, BankersOnline OFAC Update.

FinCEN has announced it has issued a Financial Trend Analysis (FTA) on patterns and trends contained in Bank Secrecy Act (BSA) reporting on suspected evasion of Russia-related export controls. The BSA reports analyzed for this FTA were filed in response to previous joint Alerts on this topic and indicate almost $1 billion in suspicious activity.

The FTA describes several trends found in this BSA reporting:

• Suspicious transactions conducted after Russia’s invasion indicate that companies in intermediary countries appear to have purchased U.S.-origin goods on behalf of Russian end-users.
• Suspicious transactions link trade activity, likely involving sensitive items, between end users in Russia and other jurisdictions, particularly China, Hong Kong, and Turkey.
• The majority of companies within the dataset are linked to the electronics industry and are potentially associated with—or directly facilitating—Russian export control evasion.
• Companies in the industrial machinery industry are also potentially supplying Russia with equipment.

FinCEN anticipates that new trends in BSA data may emerge as more individuals and entities are publicly identified as being potentially connected to evasion of Russia-related export controls.