Industrial Policy & Trade Monitor· 2662 actions· ✨ 89 recent

FinCEN issued a final rule under Section 311 of the USA PATRIOT Act (31 U.S.C. § 5318A) prohibiting US covered financial institutions from opening or maintaining a correspondent account for, or on behalf of, Cambodia-based Huione Group, a foreign financial institution found to be of primary money-laundering concern. Treasury determined that Huione Group and its subsidiaries — including Haowang Guarantee, Huione Pay PLC, and Huione Crypto — laundered at least $4 billion of illicit proceeds between August 2021 and January 2025, including funds tied to North Korean cyber-heist actors and Southeast Asian "pig-butchering" investment-scam compounds. The rule also imposes a special-due-diligence requirement on US covered institutions to guard against indirect access via foreign correspondent accounts. Effective November 17, 2025.

The US Treasury's Office of Foreign Assets Control designated two Iranian financial facilitators — Alireza Derakhshan and Arash Estaki Alivand — along with more than a dozen Hong Kong- and UAE-based individuals and entities for operating a shadow-banking network that laundered proceeds from Iranian oil sales through front companies and cryptocurrency. The designated addresses account for over $600 million in total inflows, including more than $100 million in cryptocurrency purchases tied to oil sales between 2023 and 2025. Proceeds are alleged to benefit the IRGC-Qods Force and Iran's Ministry of Defense and Armed Forces Logistics (MODAFL). This is the second round of OFAC sanctions targeting Iran's shadow-banking infrastructure since National Security Presidential Memorandum 2 (NSPM-2) directed a maximum-pressure campaign on Iran in February 2025.

The US Treasury's Office of Foreign Assets Control designated a Russian national (Vitaliy Sergeyevich Andreyev), a Russia-based DPRK economic and trade consular official (Kim Ung Sun), a Chinese front company (Shenyang Geumpungri Network Technology Co., Ltd), and a DPRK trading company subordinate to the DPRK Ministry of People's Armed Forces General Political Bureau (Korea Sinjin Trading Corporation) for facilitating a fraudulent overseas IT-worker scheme that funds North Korea's weapons of mass destruction and ballistic missile programs. The action expands on the prior designation of Chinyong Information Technology Cooperation Company, an entity tied to the DPRK defense ministry that deploys IT worker delegations in Russia and Laos. Treasury said Andreyev and Kim Ung Sun facilitated cryptocurrency-to-cash conversions worth nearly USD 600,000 since December 2024, and that Shenyang Geumpungri's delegation of DPRK IT workers has earned Chinyong and Sinjin over USD 1 million in profits since 2021. Designations were made under Executive Order 13687, blocking all US-jurisdiction property of the four parties and barring US persons from transactions with them.

On 14 August 2025 OFAC re-designated the cryptocurrency exchange Garantex Europe OU under its cyber authority (E.O. 13694, as amended) for processing over USD 100 million in transactions tied to ransomware and darknet-market actors since 2019, and designated its successor exchange Grinex — created by former Garantex staff to move customer deposits and continue operations after a March 2025 US Secret Service-led takedown of Garantex's infrastructure. OFAC also designated three Garantex executives, the A7A5 ruble-backed stablecoin issuer Old Vector (Kyrgyzstan), and Russian settlement-platform firm A7 and its subsidiaries A71 and A7 Agent — entities linked to sanctioned Moldovan oligarch Ilan Shor and sanctioned Promsvyazbank — for supplying the A7A5 token used to compensate Garantex customers and route funds through Grinex.