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Last two weeks' major developments in sanctions - Mar. 28th to Apr. 9th, 2022

This issue exceptionally covers two weeks (as opposed to our normal weekly updates). Don't forget to check out Sanctions Expert dedicated page to Russia sanctions to see all the sanctions imposed following Russian military attack to Ukraine : Special Edition - New Sanctions Against Russia

Monday, March 28th

- The Australian government for the first time used the authority granted to it under the Magnitsky sanctions program. As part of this action, 39 individuals were added to the Australian sanctions list and are subject to asset freezing sanctions. (Here, press release)

Tuesday, March 29th

- OFSI issued a general license allowing winding down activities that involve Sovcomflot through May 15, 2022. (Here)

Wednesday, March 30th

- OFAC designated one individual and four entities in Iran under the authority granted to it in Executive Order 13382, which targets weapons of mass destruction proliferators and their supporters. (Here, the Department of the Treasury's press release, the Department of State's press release)

- The UK imposed restrictions on providing technical services to Russian Oligarchs' aircrafts and ship in the UK. Also it extended the jurisdictional sanctions against non-government controlled areas of Donetsk and Luhansk regions. (Here, press release)

Thursday, March 31st

- OFSI updated its Russia Sanctions Guidance (here) and its General Guidance (here).

- The U.S. Department of States published 2022 Hong Kong Policy Act Report. Even though there was no sanctions measure attached to this reporting, it is an important report in light of the U.S.-China relationship and the trajectory of sanctions against China under the Hong Kong sanctions program of OFAC. (Here)

- The U.S. Secretary of the Treasury determined that aerospace, electronics, and marine sectors of the Russian Federation economy should be added to the scope industries under section 1 (a)(i) of EO 14024. Previously, the technology sector or the defense and related materiel sector of the Russian Federation economy were named under this section. (Note that this is only a designation authority!) OFAC at the same time designated several individuals and entities under EO 14024 and section 224 of CAATSA. (Here, Treasury's press release, State Department press release)

- UK designated more individuals and entities under its Russia sanctions regime. (Here)

Friday, April 1st

- OFAC added five entities to the SDN list under the NPWMD program. (Here, the Department of the Treasury's press release, the Department of State's press release)

- OFAC published a settlement agreement in the amount of $78,750 with S&P Global, Inc. because it received payments from a SSI entity which was in breach of sectoral sanctions against Russia. (Here) The takeaway from this settlement: Do not accept payments from SSI companies when the defined time limits are passed.

- BIS added 120 entities in Russia and Belarus to the Entity list. (Here)

Monday, April 4th

- Australia prohibited the supply, sale or transfer of certain luxury goods directly or indirectly to, for use in, or for the benefit of Russia. (Here)

- DoJ published the news of seizing a yacht in Spain which belongs to a Russian SDN. The seizure warrant was issued in the U.S. based on allegations that the Tango was obtained in violation of U.S. bank fraud, money laundering, and sanction statutes. (DoJ press release)

Tuesday, April 5th

- OFAC designated a major darknet market, Hydra Market, pursuant to the authority granted in E.O. 13694, as amended. Concurrently, OFAC designated a crypto exchange, called Grantex, pursuant to E.O. 14024 for operating or having operated in the financial services sector of the Russian Federation economy. (Here, the Department of the Treasury's press release, the Department of State's press release) In addition to the Treasury, DoJ indicted a Russian resident for his role in operating Hydra Market. (DoJ press release)

- OFAC took a major step in ramping up sanctions against Russia by designating several individuals and entities including Alfa-Bank and Sberbank as SDN. (Here, the Department of the Treasury's press release, the Department of State's press release) To mitigate the unintended impact of recent sanctions, OFAC issued Russia-related General License 8B, General License 9B, General License 10B, General License 21, General License 22, and General License 23.

Wednesday, April 6th

- DoJ unsealed an indictment based on which a Russian national, who was designated as a SDN in 2014, is charged with violating U.S. sanctions imposed against Russia in 2014. The case has so many interesting facts ranging from hiring a U.S. person to investment in a U.S. bank. The U.S. person who was hired by this SDN was also subject to DoJ actions earlier (here). (DoJ press release)

- OFAC designated Vladimir Putin's daughters. (Here)

Thursday, April 7th

- Australia imposed sanctions on additional 67 individuals for their role in Russia’s invasion of Ukraine. (Here)

- OFAC designated a world's largest diamond mining company as a Russian state-owned enterprise pursuant to E.O. 14024. OFAC also re-designated United Shipbuilding Corporation which used to be a designated entity under E.O.13661. Today's designation was pursuant to E.O. 14024. OFAC also designated several of the United Shipbuilding Corporation subsidiaries and individuals related to it. (Here, the Department of the Treasury's press release, the Department of State's press release) Concurrently, OFAC issued Russia-related General License 9C, General License 10C, General License 21A, General License 24, and General License 25.

- The U.S. Department of Commerce issued orders denying the export privileges of three Russian Airlines – Aeroflot, Azur Air, and UTair – due to ongoing export violations related to comprehensive export controls on Russia imposed by the Commerce Department. (Aeroflot Temporary Denial Order, Azur Air Temporary Denial Order, UTair Temporary Denial Order, and press release)

Friday, April 8th

- OFSI also imposed sanctions against Putin's daughters. (Here, press release)

-The fifth round of EU sanctions against Russia was published. It consisted of two Decisions:

  1. COUNCIL DECISION (CFSP) 2022/582 - Imposing asset freezing sanctions against additional 217 individuals and 18 entities. (Press release)

  2. COUNCIL DECISION (CFSP) 2022/578 - Significantly expanding the scope of pervasively-existing sanctions and introducing new restrictive measures. (Press release)

- The EU Council also imposed further sanctions on Belarus. The new sanctions included (i) prohibition on the sale of transferable securities denominated in any official currency of a Member State to Belarus, and prohibition on the sale, supply, transfer or export to Belarus of banknotes denominated in any official currency of a Member Stat, and (ii) prohibition on any road transport undertaking established in Belarus from transporting goods by road within the territory of the Union, including in transit. (COUNCIL DECISION (CFSP) 2022/579)

Recommendation of the week

- If you are interested to listen to some crypto-related sanctions compliance talk and ask your questions tune into the next webinar organized by Crystal Blockchain Analytics on April 26, 2022 at 2pm CET: Crypto Compliance with Ongoing Sanctions


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