OFAC designates two ICC officials and a Venezuela-linked BVI shell entity

What happened

On 18 August 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) added two International Criminal Court (ICC) officials to its Specially Designated Nationals (SDN) list: Tomoko Akane, a Japanese national, and Abdoulaye Seye, a Senegalese national, both designated under Executive Order 14203, the ICC-related sanctions program. OFAC also added Bluwaves Properties Limited, a British Virgin Islands entity established on 5 March 2021, to the SDN list under the Venezuela sanctions program, Executive Order 13850.

Alongside these designations, OFAC issued International Criminal Court-related General License 12, described as authorizing the wind down of transactions involving persons blocked on 18 August 2026.

Why it matters

This action extends the ICC-related sanctions program to individual officials rather than the institution alone, and pairs it, on the same day, with a Venezuela-linked shell company designation in an offshore jurisdiction known for opacity in beneficial ownership. The general license issued alongside the designations signals that OFAC anticipated existing transactions involving these persons and built in a defined exit window rather than an immediate hard freeze.

The Bluwaves Properties designation is a reminder that Venezuela-related sanctions exposure is not confined to obviously Venezuelan entities. A British Virgin Islands company, established over five years before its designation, can sit unnoticed in a corporate structure until the day it appears on the SDN list.

Practitioner angle

• Update SDN screening systems to capture the 18 August 2026 additions: Tomoko Akane, Abdoulaye Seye, and Bluwaves Properties Limited.
• If your institution has any exposure to Bluwaves Properties Limited, review General License 12’s wind-down terms before assuming a blanket freeze applies, and confirm the wind-down window and any reporting conditions before processing further transactions.
• Treat offshore entities with no obvious nationality flag, such as BVI-registered companies, as requiring the same beneficial-ownership scrutiny as directly named Venezuelan or ICC-linked persons, since this designation shows sanctions exposure can sit inside an unremarkable corporate shell for years before designation.

The single most important step: confirm today whether General License 12’s wind-down terms apply to any of your open transactions involving these three newly designated persons, rather than defaulting to an immediate block that may not match the license’s terms.