OFAC Removes Russia and Lebanon Sanctions Designations
Summary
The US Department of the Treasury's Office of Foreign Assets Control (OFAC) has removed several individuals from its Specially Designated Nationals (SDN) List. These removals include designations related to Russia and Lebanon, with some individuals previously linked to the Wagner Group. This action updates OFAC's sanctions lists and impacts entities that previously had dealings with these designated parties.
What changed
OFAC has removed specific individuals from its Specially Designated Nationals (SDN) List, including Dany Khoury (Lebanon) and Adama Bagayoko, Alou Boi Diarra, and Sadio Camara (all linked to Russia sanctions and the Wagner Group). These removals signify a change in OFAC's sanctions enforcement and indicate that these parties are no longer subject to the strictest U.S. sanctions.
Regulated entities, particularly those involved in international trade, finance, and sanctions compliance, should update their internal watchlists and due diligence procedures to reflect these removals. Failure to recognize these changes could lead to inadvertent dealings with previously sanctioned parties, although the risk is now reduced for these specific individuals. No new compliance actions are mandated by this notice, but entities should ensure their systems accurately reflect the current SDN list.
What to do next
- Update internal sanctions watchlists and screening tools to remove the delisted individuals.
- Review any past transactions or relationships with the delisted individuals to ensure compliance up to the date of removal.
- Ensure ongoing due diligence processes reflect the current OFAC SDN List.
Source document (simplified)
- Specially Designated Nationals List (SDN List)
- Consolidated Sanctions List (Non-SDN Lists)
- Additional Sanctions Lists
- Search OFAC's Sanctions Lists
- Sanctions Programs and Country Information
- Recent Actions
- OFAC License Application Page
- Additional OFAC Resources
- Frequently Asked Questions
- Civil Penalties and Enforcement Information
- OFAC Reporting System
- Selected General Licenses Issued by OFAC
- Contact OFAC
Russia-related Designations Removals; Lebanon Designation Removal
SPECIALLY DESIGNATED NATIONALS LIST UPDATE
The following deletions have been made to OFAC's SDN List:
KHOURY, Dany (Arabic: داني خوري), Lebanon; DOB 02 May 1967; POB Ramhala, Lebanon; nationality Lebanon; Gender Male; Passport LR0036899 (Lebanon) expires 17 Aug 2021 (individual) [LEBANON].
BAGAYOKO, Adama, Mali; DOB 14 Sep 1979; POB Bamako, Mali; nationality Mali; citizen Mali; Gender Male; Secondary sanctions risk: See Section 11 of Executive Order 14024.; Passport AA0262268 (Mali) (individual) RUSSIA-EO14024.
DIARRA, Alou Boi, Bamako, Mali; DOB 01 Sep 1981; POB Kati Koulikoro, Mali; nationality Mali; citizen Mali; Gender Male; Secondary sanctions risk: See Section 11 of Executive Order 14024.; Passport DA0004002 (Mali) (individual) RUSSIA-EO14024.
CAMARA, Sadio, Bamako, Mali; Malibougou, Kati, Koulikoro, Mali; DOB 22 Mar 1979; POB Kati, Koulikoro, Mali; nationality Mali; citizen Mali; Gender Male; Secondary sanctions risk: See Section 11 of Executive Order 14024.; Passport DA0004031 (Mali) expires 15 Oct 2015 (individual) RUSSIA-EO14024.
Unrelated Administrative List Updates:
None
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