In this video, Francis Turner from ThreatSTOP provides valuable insights into identifying and understanding sanctioned entities. With the potential implications of doing business with sanctioned parties, this video sheds light on the challenges and offers solutions to ensure compliance.
Key Takeaway:
Understanding OFAC sanctions involves deciphering a web of complexities, ranging from sanctioned countries to individuals and entities. Simplify your compliance journey by grasping the nuanced details outlined in this video. At ThreatSTOP, we're dedicated to simplifying your path to compliance by identifying sanctioned elements and using your existing network infrastructure to prevent communications. ThreatSTOP’s DNS and IP Defense are a one-stop shop for OFAC compliance.
Contact us for expert guidance in OFAC compliance and see how we can protect your business in as little as 15 minutes.
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Video Transcript
0:00 Intro
0:20 Sanctions List
Hi there, this is Francis Turner from ThreatSTOP. I'm a security researcher involved in identifying elements that are sanctioned to do with sanctions compliance and sanctions violations.
0:20 Sanctions List
And so, one of the questions that we've been asked a lot, and it's a very simple one, it sounds pretty simple is, what countries are subject to OFAC sanctions, and who are on the OFAC sanctions?
Well, as I said in one of my other videos, you can go to the OFAC website on ofac.treasury.gov and go find the list, but that's confusing. OFAC doesn't specifically sanction countries for the most part. It does sanction a couple, like effectively, you can't do business with Iran or North Korea or Cuba, and there are a few others that are like Sudan, for example, that basically the entire country, you know, they consider there's no real reason why you should let anyone that's to do with the U.S. should do any business with them.
So, therefore, basically, it's blocked unless you have a very specific reason. Not typically, and this particularly applies, of course, to Cuba and North Korea. These countries are communists. They don't have any private enterprise. Everything is controlled by the government, and since the government has been sanctioned, basically everything in that country has been sanctioned.
And then you have countries like Russia, where The Russian government has been sanctioned, and certain Russian individuals have been sanctioned, but there are potentially other parts of Russia and Russian-related people, Russian-related organizations that are not sanctioned.
However, a lot of the time, people will say, well, it's much easier to not do business with Russia full stop than to try and work out which part of the Russian industrial complex or whatever food exporting, whatever it is exporting business that you might want to do business with is actually under sanctions control or not, and so therefore, we block the whole of Russia. But there are also Russian-related entities that are sanctioned that have subsidiaries outside Russia, and that's where it gets complicated.
As I said, you can go look at the OFAC website and go download the SDN issues specifically designated national list and see who is on that list and who they are. You'll see, for example, that there are certain individuals, there are certain banks. If you go to say, you know, they will say things like, the following individuals who have been added to the OFAC SDN list: Anakin Vasily, somebody rather, Charakov somebody, Svetek Evan Serbia, you know, and all sorts of other, you know. There will be all sorts of people like that, and then they will have things like, you know, AEM propulsion and some location in Saint Petersburg. They will have, you know, AK systems in Moscow and so on, which are added specifically to the list.
Now, some of these are just in Russia, and so it's really straightforward. It's the same thing, so you know, if you're blocking Russia and you're not talking to anything in Russia, then you're safe, but on the other hand, you've got companies like Gazprom. Now, Gazprom is an enormous company, which had, at least prior to February 20, 2022, subsidiaries in Germany, probably other parts of Europe, Kyrgyzstan, you know, other parts of the former Soviet Union, and probably other places that I haven't paid attention to too much that, you know, we've had subsidiaries in.
Now, some of those subsidiaries were nationalized as part of it's like I believe the Germans effectively nationalized gas from in Germany, but others are still trading and are still sanctioned, and you will therefore not be allowed to do business with them without special permission for the U.S. government, and so on.
So that's effectively the source of people that are sanctioned by OFAC. As I said, it's complicated because you've got both individuals, and some of those individuals are extremely rich. So they're billionaires, they're so-called oligarchs, and the oligarchs typically have, you know, many subsidiaries, companies that are owned by them.
I mean, famously, in the U.K., Chelsea Football Club was owned by Abramovic, who was sanctioned in February last year. Now, for various reasons, Chelsea Football Club managed to sort of change its ownership so that he was no longer the owner, and therefore, they're not sanctioned.
But there was a time when, at least theoretically, any football organization that was doing, you know, playing games against Chelsea was potentially violating OFAC sanctions on Mr. Abramovich.
So that's sanctions. They're complicated this way, and one of the things that we do at ThreatSTOP is to try and make it simple for you by identifying these organizations and control organizations of sanctioned individuals so you don't talk to them by mistake.