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Last week's major developments in sanctions - Dec. 14 to Dec. 18, 2020.

Updated: Jan 10, 2021

Monday, December 14th:

- This week started with the designation of an individual under Global Human Rights Sanctions Regulations 2020 by OFSI. The listed person was Remigio CEBALLOS ICHASO, a military officer in Venezuela, who was previously designated by OFAC. (Link)

- OFSI also delisted, Delphin KAIMBI, the military spy chief in Democratic Republic of Congo who died earlier this year. (Link)


- OFAC designated two Iranian individuals pursuant to Executive Order 13553 for their involvement in the abduction and detention of Robert Levinson, an FBI agent. (Link)


- The U.S. Dept. of State officially rescinded Sudan’s designation as a state sponsor of terrorism following Sudan’s actions to normalize relations with Israel and resolution of terrorism claims. (Link)

Now only North Korea, Iran, and Syria are designated as State Sponsor of Terrorism which entails, among other things, restrictions on U.S. foreign assistance, a ban on defense exports and sales, and certain controls over exports of dual use items.


- Finally on this busy day, OFAC published Non-SDN Menu-Based Sanctions (NS-MBS) List following the imposition of certain menu-based sanctions against the Turkey military procurement organization by Dept. of State. It also imposed blocking sanctions against 4 individuals pursuant section 231 of CAATSA. (See my post about this major development.)

Tuesday, December 15th: - France added four Turkish individuals to its terrorism list. (Link)


- The U.S. Dept. of State designated the Saraya al-Mukhtar, an Iran-backed group in Bahrain, as a Specially Designated Global Terrorist [SDGT] pursuant to Executive Order 13224. (Link)

Wednesday, December 16th:

- OFSI published regulations related to "[t]he Unauthorised Drilling Activities in the Eastern Mediterranean (Sanctions) (EU Exit) Regulations 2020." The EU version of this regulations has been used by EU against Turkey for its activities in the Mediterranean sea. (Link)


- The U.S. Dept. of State and Treasury imposed sanctions on five companies and one individual for supporting the sale of Iranian petrochemicals. (Dept. of State press release - OFAC press release) Four designations due to providing material assistance shows the importance of looking into the risk of doing a sanctionable activity. (See my article for Association of Certified Sanctions Specialist on this topic)


Thursday, December 17th:

- EU designated the third batch of targets pursuant to its Belarus regime. This time, the EU Council decided to impose sanctions against 36 additional entities. (Link)

- France listed two individuals pursuant to its national anti-terrorism program. (Link to the first designation, link to the second designation)


Friday, December 18th:

- France Treasury (direction générale du Trésor) published two documents to provide guidance for those involved in humanitarian activities in countries under sanctions and zones where the risk of terrorism financing is higher. (Link)


- OFSI did a number list additions/modifications. In particular, it added 29 individual and 7 entities to the it consolidated list. It also amended several entries across different regimes. (Link)


- OFAC listed one entity and two individuals for their role in supporting the Maduro's government. (Link)

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