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Sanctions week: what OFAC's latest actions demand from your screening

By GlobalKYCS Compliance TeamPublished Updated

OFAC added 55 entries to its lists, fined a logistics company over an import and a mishandled subpoena, and designated the International Criminal Court. What it means for your screening in Latin America.

It was a quiet week for new rules but a busy one for sanctions. Between October 7 and 9, the U.S. Department of the Treasury and its Office of Foreign Assets Control (OFAC) added dozens of entries to their lists, settled a case with a logistics firm and issued the first penalty under the outbound investment program. For regulated institutions in Latin America and the Caribbean the message is clear: screening must be updated quickly and must cover far more than payments.

1. KYC/AML: OFAC moves its lists and penalizes control failures

On October 8, OFAC added 55 entries to the SDN List under its Iran sanctions program: 6 individuals, 27 entities and 22 vessels. Treasury framed the action as part of Operation Economic Outcast against the so-called shadow fleet that carries Iranian oil and petrochemical products. Three of the vessels identified sail under the Panamanian flag. OFAC also removed two vessels from the list and issued a general license to wind down transactions with one of the designated companies.

Two more developments followed on October 9. First, OFAC reached a $175,015 settlement with Pegasus Worldwide Logistics, a freight forwarding firm. According to OFAC, between September 2023 and February 2024 the company facilitated the import of a machine supplied by a company designated under the narcotics trafficking program, and it took six months to fully respond to an OFAC subpoena. The conduct was deemed non-egregious and was not voluntarily disclosed. Second, OFAC added the International Criminal Court (ICC) to the SDN List and published four general licenses authorizing certain transactions, including telecommunications and software services, pension payments and transactions related to persons detained by the Court.

A day earlier, on October 7, Treasury imposed the first civil penalty under its Outbound Investment Security Program: $200,000 against Amidi, LLC for failing to notify an investment by a controlled foreign entity in a Chinese artificial intelligence company. Obligations also reach subsidiaries.

FinCEN and the FATF published no new updates during the period.

2. GAFILAT

No new updates since our October 8 edition.

3. Dominican Republic

There were no new rules from the Superintendency of Banks and no announcements from the Financial Analysis Unit (UAF) in these four days. On the agenda, the UAF lists its 9th International Congress against Money Laundering for October 23, in a hybrid format.

4. Latin America: Panama on the shadow fleet radar

The FIUs of Argentina and Ecuador and the Central Bank of Argentina published no AML updates during the period. The most direct regional link this week is the Panamanian flag on three of the vessels sanctioned on October 8. Banks, insurers, shipping agents and port service providers should check their exposure to those vessels and their owners, bearing in mind that entities owned 50% or more by blocked persons are also blocked.

Practical takeaways for regulated companies

  • Update your lists today: confirm that your tool reflects OFAC's additions and removals of October 8 and 9, including vessel identifiers.
  • Screen the whole chain: suppliers, carriers and goods, not just the payer; the Pegasus case stems from an import.
  • Respond fully and on time: document every regulatory request and your response; an incomplete response can also be penalized.
  • Review payments to international organizations: before blocking or processing a transaction linked to the ICC, check the scope of general licenses 13 to 16 with your legal counsel.
  • Include your subsidiaries: identify which notification or blocking obligations apply to entities you control abroad.

At Global KYC & Compliance Solutions, we automate screening of individuals, entities and vessels so your team can react the same day the lists change.

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