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Last three week's major developments in sanctions - December 18th, 2023, to January 7th, 2024

Happy New Year to all of our readers. This issue covers the past three weeks rather than our normal week-long coverage. We will go back to our weekly cadence going forward.


Monday, December 18
  • The EU Council adopted its long-anticipated 12th package of sanctions against Russia. The new package includes:

    • Asset-freezing sanctions on 61 individuals and 86 entities for their involvement in threatening the territorial integrity, sovereignty, and independence of Ukraine (Here, and press release)

    • A new ground for designation and provided grounds for additional derogations (Here)

    • A ban on direct or indirect import, purchase or transfer of diamonds from Russia, and other trade-related restrictions. (Here, and press release) (To read more about the 12th package of the EU sanctions against Russia read this alert by HHR.)

    • The UK government published an "Independent Reviewer of Terrorism Legislation reviewed the operation of the counter-terrorism (International Sanctions) (EU Exit) Regulations 2019." The report assesses the operation of the asset freeze provisions in these regulations and makes a number of recommendations to the UK government. (Here)


Tuesday, December 19
  • The U.S. Government took action against Iran’s production of unmanned aerial vehicles. Specifically:

    • The U.S. Department of Justice unsealed indictments against two individuals for crimes related to the procurement of U.S.-manufactured dual-use microelectronics supporting Iran’s production of unmanned aerial vehicles. (Department of Justice press release)

    • OFAC imposed asset-freezing sanctions against ten entities and four individuals for supporting Iran’s unmanned aerial vehicle production. (Here, Department of Treasury press release)

  • A U.S. citizen pleaded guilty to filing false export forms with the U.S. government and selling and exporting avionics equipment in Russia without the required licenses. (Here)


Wednesday, December 20
  • OFAC published updated guidance on the implementation of the Price Cap Policy.  (Here, Department of Treasury press release)

  • Concurrently, OFAC imposed asset-freezing sanctions on four individuals and one vessel who were involved in the trade of Russian oil above the price cap. OFAC also removed asset-freezing sanctions on 116 individuals and entities. (Here, Department of Treasury press release)

  • Lastly, OFAC issued two Russia-related General Licenses to mitigate the unintended effects of this day's actions. (General License 81, General License 82)

  • OFSI updated its OFSI’s price cap-related guidance in relation to the attestation model, with per-voyage attestations and itemized ancillary costs. The updated guidance also provides clarification on reporting requirements for UK nationals in third countries and reporting timelines. Furthermore, it created sub-tiers 3A and 3B in the context of compliance obligations. (Here)


Thursday, December 21
  • The U.S. Department of State imposed visa restrictions (a type of sanction) on 14 individuals for their involvement in undermining the democratic process and significant corruption in Guatemala, Honduras, Nicaragua, and El Salvador. (Here)

  • OFAC announced a settlement agreement with Privilege Underwriters Reciprocal Exchange (PURE), an insurance organization in NY, for $466,200 for apparent violations of Ukraine/Russia-related sanctions between 2018 and 2020.  PURE engaged in transactions related to four insurance policies involving a blocked Panama-based company owned by Viktor Vekselberg. (Here)

  • OFSI added two forms related to how to report blocked assets of designated persons: one for UK persons and non-UK persons. (Here)


Friday, December 22
  • OFAC's Christmas gift for sanctions practitioners: A new Executive Order, three, determinations, three general licenses, a bunch of new and amended FAQs, and a couple of designations. The new EO, among other things, introduced a new authority for so-called secondary sanctions against foreign financial institutions. To know more about the details, check this alert from Steptoe.


Monday, December 25
  • 🎄🎄🎄 There was no major development on this day 🎄🎄🎄


Tuesday, December 26
  • There was no major development on this day.


Wednesday, December 27
  • France imposed asset-freezing sanctions against one individual under France's autonomous counter-terrorism sanctions. (Here)


Thursday, December 28
  • OFAC imposed asset-freezing sanctions on one individual and three entities for their involvement in facilitating Iranian financial assistance to the Houthis. (Here, Department of Treasury press release, Department of State press release)

  • New Hampshire charity, NuDay, was sentenced to five years of probation in federal court for export offensives in Syria and lying about the end-destination of goods. (Here)

  • OFSI updated its Haiti Guidance to reflect UN Security Council Resolutions 2699 (2023) and 2700 (2023) concerning the arms embargo against Haiti. (Here)


Friday, December 29
  • There was no major development on this day.


Monday, January 1
  • 🎉🎉🎉 Happy New Year to all Sanctions Expert readers. Thank you for your constant support in 2023. 🎉🎉🎉

  • The Day has arrived! FinCEN began accepting beneficial ownership information reports pursuant to the Corporate Transparency Act of 2021. (Here, Department of Treasury press release)


Tuesday, January 2
  • OFSI amended General License INT/2022/1280876 to change the name of VTB Bank (Europe) SE to OWH SE within the definition of an “EU subsidiary.” (Here)


Wednesday, January 3
  • The EU Council imposed asset-freezing sanctions on PJSC Alrosa, the largest diamond-mining company in the world, and its CEO Pavel Alekseevich Marinychev. (Here, EU Council press release)


Thursday, January 4
  • There was no major development on this day.


Friday, January 5
  • France imposed asset-freezing sanctions against one individual under France's autonomous counter-terrorism sanctions. (Here)


Sunday, January 7
  • Over the weekend, the Chinese government imposed asset-freezing sanctions against five U.S. Defense Corporations for violation of the One-China policy and in response to U.S. weapons sales to Taiwan. (Here)


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