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Last week's major developments in sanctions - Apr. 26th to Apr. 30th, 2021

Monday, April 26th

- France added three individuals to its list of asset freezing sanctions pursuant to France autonomous anti-terrorism sanctions. (Here)

- EU added twelve entries to the list of those targeted by the EU Myanmar Regime. (Council Decision, Press release) Some of these new targets were already targeted by OFAC and/or OFSI.

- OFSI introduced a new sanctions regime: The Global Anti-Corruption ("GAC")

OFSI published a brief note explaining the new regime. (Here) The announcement of the new regime was followed by the first set of designations under the new sanctions regime. OFSI designated twenty two individuals pursuant to this new regime. (Here) The United States' secretaries of Treasury and State issued statements praising the new UK sanctions regime.

- Later in the day, OFAC added two Guatemalans to the SDN list under the Global Magnitsky program. (Here, Treasury press release, Department of State press release) One of the two new additions was among those who were targeted by OFSI earlier in the day.

Tuesday, April 27th - OFAC amended the Somalia Sanctions Regulations, 31 C.F.R. part 551. (Here) The amendments were so material that OFAC decided to reissue the entire part. OFAC added several definitions, interpretations, and licenses to the new set of regulations. You can find the recently-issued set of regulations here. In case you would like to take a look at the previous version of the regulation in question, you can find it here.

Wednesday, April 28th

- In an export control-related piece of news, DOJ announced that a Chinese national pleaded guilty in connection with illegally procuring and causing the illegal export of $100,000 worth of U.S. origin goods to a Chinese military university. (Here)

Thursday, April 29th

- The EU Council extended the Myanmar sanctions regime for another year. (Council's Decision, press release)

- The UK government published Myanmar (Sanctions) Regulations 2021 replacing the previous regulations governing sanctions against Myanmar, the Burma (European Union Financial Sanctions) Regulations 2018. The government issued a guidance explaining sanctions against Myanmar. (Here) Accordingly, OFSI made some amendments to reflect the changes in the authority for sanctions against Myanmar. (Here)

- OFAC announced two settlement agreements:

  1. MoneyGram Payment Systems Inc. MoneyGram processed payments for a number of individuals listed on the SDN list, as well as transactions related to Syria believing they were personal remittances while in fact they were commercial payments. The interesting point in this case is that some of those listed individuals were held in prisons in the United States and MoneyGram erroneously thought it could process transactions related to them.

  2. SAP SE This settlement presents very interesting sets of facts. Even though services exported to Iran were not sold by a U.S. company, the servers for those service/softwares were located in the U.S. or the cloud-based services were provided by a U.S. subsidiary of SAP. Concurrently, DOJ published its Non-Prosecution Agreement with SAP. (Here)

Friday, April 30th

- Several list amendments and deletions by different authorities took place on Friday. (UN, U.S., EU, UK, and France)

- EU High Representative reacted to the sanctions (travel bans) imposed by Russia against some high-level EU officials by condemning Russia's actions. (Here)


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