On August 18, 2026, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) added two individuals and one entity to the Specially Designated Nationals and Blocked Persons (SDN) List and issued International Criminal Court-related General License No. 12, "Authorizing the Wind Down of Transactions Involving Certain Persons Blocked on August 18, 2026." The designations run under two separate authorities: ICC-related Executive Order 14203 for the two individuals, and Venezuela-related Executive Order 13850 for the entity. Compliance teams that screen against the SDN List must push the update immediately under OFAC's strict-liability regime, as set out in OFAC's August 18, 2026 recent-actions release.
The two individuals are Tomoko AKANE, a Japanese national resident in the Netherlands (DOB 28 Jun 1956, place of birth Aichi, Japan), and Abdoulaye SEYE, a Senegalese national also resident in the Netherlands (DOB 09 May 1967, place of birth Dakar, Senegal). Both are blocked under the ICC program. The entity is BLUWAVES PROPERTIES LIMITED, a British Virgin Islands company (established 05 Mar 2021, registration number 2056404), blocked under the Venezuela program. Under the 50 Percent Rule, any entity 50 percent or more owned in the aggregate by these blocked persons is itself blocked even when not separately listed, so screening logic must propagate the ownership chain and not merely match the three new names.
What does General License 12 authorize?
General License No. 12 authorizes the wind-down of transactions involving the persons blocked on August 18, 2026. A wind-down license is a time-bound safe harbor: it permits activities that would otherwise be prohibited, but only to the extent they are consistent with winding down existing dealings, not continuing or expanding them. Institutions that had a relationship with a now-blocked party should map the scope of the license against their exposures before relying on it, because conduct outside the license remains a prohibited transaction with an SDN. The license does not unblock the designees; it carves out a narrow channel for orderly exit.
Who must act, and by when?
Every USD-clearing bank, exporter, freight forwarder, insurer, and multinational that screens against the SDN List must update its filtering systems to include the three new entries. OFAC sanctions operate under strict liability: a transaction with a listed person violates the rules regardless of intent, and civil penalties attach even where the institution did not know the counterparty had been designated. The screening update is therefore same-day, not next-cycle. Voluntary self-disclosure of a violation can reduce a penalty by up to 50 percent under 31 CFR Part 501, Appendix A, so documenting the detection gap and the remediation matters as much as the fix itself.
Because US sanctions reach through USD clearing and the US-person nexus, the obligation is not limited to US-domiciled firms. A non-US bank that routes a USD payment through a US correspondent, or that touches a US person, implicates OFAC jurisdiction, and the reexport doctrine extends the SDN blocking to foreign-made items that incorporate controlled US content. Non-US groups should confirm whether any subsidiary, counterparty, or beneficial owner matches AKANE, SEYE, or BLUWAVES PROPERTIES LIMITED, and whether pending transactions fall within General License 12's wind-down window.
Which targets were designated, and under which authority?
| Target | Type | Program | Key identifiers |
|---|---|---|---|
| Tomoko AKANE | Individual | ICC, EO 14203 | Japan national; DOB 28 Jun 1956; resident in Netherlands |
| Abdoulaye SEYE | Individual | ICC, EO 14203 | Senegal national; DOB 09 May 1967; resident in Netherlands |
| BLUWAVES PROPERTIES LIMITED | Entity | Venezuela, EO 13850 | BVI; est. 05 Mar 2021; reg. 2056404 |
Continuous, per-jurisdiction real-time monitoring surfaces this kind of SDN designation the moment OFAC publishes it, rather than at the next batch refresh.
Take advantage of this real-time watch
Run the August 18, 2026 SDN update through your screening platform and confirm a clean back-match across customer, counterparty, vendor, and beneficial-ownership files. Pull the full text of General License No. 12 from the OFAC recent-actions page and circulate it to sanctions, trade finance, and front-office teams with a deadline for wind-down exposure reporting. Document the review for your audit trail: under strict liability, the dated evidence that you screened and acted is your primary defense.
