Transnational Criminal Organizations Designations and Designations Removals; Publication of Russia-related Frequently Asked Question

The Office of Foreign Assets Control (OFAC) has published a press release to inform about new sanction measures. Specifically, the Office announced that it has added two persons to its Specially Designated Nationals and Blocked Persons List (SDN List) and removed several others from same list for (no longer) participating or (no longer) being part of criminal networks and organizations which pose a threat on the U.S. economy pursuant to Executive Order 13581 – Blocking Property of Transnational Criminal Organizations. The added individuals are the following:
ARCHAGA CARIAS, Yulan Adonay (a.k.a. „MENDOZA, Alexander“; a.k.a. „PORKY“), Honduras; DOB 13 Feb 1982; alt. DOB 21 Jan 1982; POB San Pedro Sula, Cortes, Honduras; nationality Honduras; Gender Male (individual) [TCO] (Linked To: MS-13).
CAMPBELL LICONA, David Elias (a.k.a. PEREZ PAZ, Jorge Eduardo; a.k.a. „CAMPBELL, David“; a.k.a. „DON DAVID“; a.k.a. „VIEJO DAN“), Nicaragua; DOB 18 Mar 1967; alt. DOB 20 Oct 1967; alt. DOB 02 Jan 1964; POB San Pedro Sula, Honduras; nationality Honduras; Gender Male; Numero de Identidad 0501-1967-02094 (Honduras) (individual) [TCO] (Linked To: MS-13).
As the number of removals is quite large, we refrain from listing them individually at this point. Please refer to the above noted link for more detailed information on the names, places of residency, dates of birth, if applicable, and other relevant information.
OFAC has also published an accompanying statement to explain the reasons behind the new measures.
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Additionally, OFAC has issued a new frequently asked question (FAQ) in the context of sanctions imposed on Russia due to its aggression towards Ukraine. Specifically, OFAC has added new FAQ 1113 which reads as follows – as quoted:
FAQ 1113: If a decedent’s estate includes securities issued by non-blocked Russian entities, do the new investment prohibitions in Executive Order (E.O.) 14066, E.O. 14068, or E.O. 14071 prohibit the transfer of such securities, through inheritance, to the relevant beneficiary of the decedent’s estate?
Answer: No. U.S. persons, including U.S. financial institutions, may transfer securities issued by non-blocked Russian entities from a decedent’s estate to the account of a relevant beneficiary or beneficiaries, including a successor entity (e.g., a family trust), provided such transfers (i) are part of the ordinary course administration of the decedent’s estate, (ii) do not involve an exchange for value, and (iii) have no other sanctions nexus (including the involvement of blocked persons).
Please note, however, that blocked securities in a decedent’s estate must remain blocked. The administration of a decedent’s estate requiring the transfer of blocked securities would require a specific license from OFAC. To apply for a specific license, please go to our License Application Page.