December saw continuing enforcement actions involving Russia. First, the Treasury Department’s Office of Foreign Assets Control (OFAC) settled investigations into apparent sanctions violations by a New York-based insurance company and California-based virtual currency exchange. In addition, a Belgian national was indicted by the Department of Justice (DOJ) and designated by OFAC after conspiring to illegally procure products for resale in Russia and China.

There were two notable actions involving Iran this month. The DOJ charged two individuals for allegedly procuring U.S.-origin microelectronics for an Islamic Revolutionary Guard Corps (IRGC) drone program. Also, OFAC agreed with Nasdaq to settle an investigation of sanctions violations committed by Nasdaq’s Armenian subsidiary.