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Last two weeks' major developments in sanctions - Feb. 21st to Mar. 4th, 2022

This issue exceptionally covers two weeks and it leaves the Russia-related developments out. For a detailed post about Russia-related sanctions developments you can check: Special Edition - New Sanctions Against Russia


Monday, February 21st

- The EU Council took four sanctions-related decisions:

  1. Council Decision (CFSP) 2022/240 of 21 February 2022 amending Decision (CFSP) 2016/1693 concerning restrictive measures against ISIL (Da’esh) and Al-Qaeda and persons, groups, undertakings and entities associated with them (here, press release - Added two individuals and two entities to the list of EU sanction targets

  2. Council Decision (CFSP) 2022/241 of 21 February 2022 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine (here, press release) - Added five individuals to the list of EU sanction targets

  3. Council Implementing Decision (CFSP) 2022/242 of 21 February 2022 implementing Decision 2013/255/CFSP concerning restrictive measures against Syria (here, press release) - Added five individuals to the list of EU sanction targets

  4. Council Decision (CFSP) 2022/243 of 21 February 2022 amending Decision 2013/184/CFSP concerning restrictive measures in view of the situation in Myanmar/Burma (here, press release) - Added an authorization and listed new individuals and entities.

- Two individuals came off the French list of sanctions. Both individuals were sanctioned under the counter-terrorism program of France.


- OFSI published an enforcement action against Clear Junction Limited. (Here) The transactions that led to this enforcement action were the same as the ones in the TransferGo enforcement action back in August 2021. The main takeaway: no one can rely one someone else's controls when it comes to sanctions compliance.


Tuesday, February 22nd

- The U.S. Customs and Border Protection, Department of Homeland Security and Department of the Treasury published a notice in the Federal Register about the restrictions on the importation of archaeological and ethnological material of Afghanistan to the U.S. Even though this is not a sanction measure, it is an import restrictions and I thought it might be interesting for some of you.


- OFAC designated members of an international network funding the Houthis pursuant to it counter-terrorism program. (Here, the Department of the Treasury's press release, the Department of State's press release)


Wednesday, February 23rd

- No major development on this day.


Thursday, February 24th

- No major development on this day.


Friday, February 25th

- Ten individuals' designations period under the French counter-terrorism sanctions expired and they came off the list.


- OFAC issued a pretty broad general license in the context of Afghanistan allowing all transactions involving Afghanistan or governing institutions in Afghanistan provided it is not with the Tliban or the Haqqani Network. OFAC also published six Afghanistan-related FAQs. (Here, the Department of the Treasury's press release, the Department of State's press release)


Monday, February 28th

- No major development on this day.


Tuesday, March 1st

- Another ten individuals' designations period under the French counter-terrorism sanctions expired and they came off the list.


- OFAC added four individuals to the SDN list under its counter-terrorism program. (Here, press release)


Wednesday, March 2nd

- The EU council imposed further sanctions against Belarus. The new sanctions restricted trade of dual-use goods as well as trade in several sectors of Belarusian economy. (Council Decision, press release)


Thursday, March 3rd

- No major development on this day.


Friday, March 4th

- OFAC added two individuals to the its SDN list under its Global Counter-Terrorism program. (Here, the Department of the Treasury's press release, the Department of State's press release)


- FATF added UAE to the list of jurisdictions subject to increased monitoring (the so-called grey list). (Here)


Recommendation of the week

- This past two weeks have been very tough for all the sanctions practitioners and compliance folks both in terms of the workload and the emotional distress of the recent events. I just want to thank all of you and let you know that you are not alone in this. The recommendation of the week is to take some time to meditate. You can use this 3-minute long mindful breathing if you want: 3-minute Mindful Breathing Meditation (Relieve Stress)

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