First: FiveBy Solutions has published an alert about this week’s ransomware actions. The Biden administration really took a coordinated effort against not only two ransomware operators, arresting one in the process thanks to cooperation with foreign partners and private sector companies, but also sanctioning another virtual currency exchange that is linked to SUEX—the entity sanctioned a few weeks ago for links to malign transactions and at least eight ransomware variants and issuing an updated FinCEN ransomware advisory.
I think this is another shot across the bow of US firms operating in the virtual currency space to prepare for additional scrutiny and use all available tools to ensure compliance with US sanctions and prevent transactions with actors linked to ransomware and other malign cyber activities.
Second: we’re still awaiting some upcoming designations in the aftermath of the fraudulent elections in Nicaragua, where overwhelming love and adoration of President Ortega was on full display at the polls (sarcasm intended) after he arrested and silenced all political opposition and even used the Russian tactic of spreading disinformation using a troll farm, which was taken down by Facebook recently.
Meanwhile, where are those EU sanctions against Belarus? The bloc plans to target roughly 30 individuals and entities, including the country’s foreign minister and the Belarussian national airline, Belavia, with sanctions for facilitating the movement of illegal migrants to Poland’s border. The EU is also considering broadening economic sanctions on Belarus imposed in July by targeting the local reinsurance sector and its main company state-owned BelarusRe. The Biden administration is promising sanctions of its own as a follow-up. Lukashenko, in retaliation for possible new EU sanctions, has threatened to cut deliveries of gas to Europe via the Yamal-Europe pipeline from Russia.
There’s also the promise of sanctions on Ethiopia, where the crisis is escalating, as 16 UN staff members were detained and UK personnel were warned to immediately leave the country. Ethiopia declared a state of emergency last week, allowing the government to arrest anyone suspected of being involved with a terrorist group without a court order. The Biden administration has an Executive Order (EO) signed by the President in September to impose sanctions on those responsible for the human crisis and suffering in Ethiopia. The EU is also ready to use its GLOMAG-like sanctions authority as leverage to promote peace there, so we are likely to see coordinated actions between the United States and our allies. Question is: when?
Also: Want to know why it’s important to closely examine your supply chain? Because your customers might wind up eating tomato products produced by slave labor in Xinjiang, China, which would cause you all sorts of environmental, social, and corporate governance (ESG) headaches.
OFAC this week sanctioned two high-level Cambodian military officials—Chau Phirun and Tea Vinh—under the Global Magnitsky Act (GLOMAG) for corruption. Treasury asserts that Chau conspired to profit from activities regarding the construction and updating of Ream Naval Base facilities, and that he and Tea likely conspired to inflate the cost of facilities at the base to personally profit from the upgrades. Treasury, State, and Commerce also jointly issued an advisory for firms transacting in Cambodia listing risks for transactions in real estate, financial, gambling, and infrastructure sectors. Although the designations do not mention China, satellite imagery confirms that new facilities are being built, probably to facilitate a Chinese military presence in Cambodia, after the country in 2019 signed a secret agreement with Beijing to give China exclusive rights to part of the navy base.
And for those who wondered how long the United States plans to keep up sanctions pressure on Russia for its illegal annexation of Crimea in 2014, the State Department’s US-Ukraine charter on Strategic Partnership issued this week, reaffirming the importance of the relationship with Ukraine as a strategic partner, should be an indicator that sanctions are not going away anytime soon. The document emphasizes our “unwavering commitment to Ukraine’s sovereignty, independence, and territorial integrity within its internationally recognized borders, including Crimea and extending to its territorial waters in the face of ongoing Russian aggression, which threatens regional peace and stability and undermines the global rules-based order.”
That’s what’s up.