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Last week's major developments in sanctions - Apr. 5th to Apr. 9th, 2021

Updated: Apr 12, 2021

Monday, April 5th

- Following last week's revocation of E.O. 13928, OFAC removed those individuals listed under this program. (Here) So, no more sanctions against ICC. The takeaway from this: sanctions programs that are only based on Executive Orders could disappear with a stroke of a pen.

- OFAC published two FAQs related to its Syria program.

  • FAQ 884 is similar to a number of other FAQs in programs with "secondary sanctions." OFAC tries to comfort non-U.S. persons by assuring that they won't expose themself to the risk of sanctions if the activity they are engaging in would have been authorized for a U.S. person. OFAC reminded non-U.S. persons that this FAQ is applicable to the Caesar Act only.

  • In FAQ 885 talks about the humanitarian trades with Syria and it reminds that it is allowed for U.S. persons and that it is not sanctionable for non-U.S. persons.

- UN Security Council Sanctions Committee concerning Central African Republic removed one entity from its sanctions list. (Here) Both France and OFSI removed this entity a day after yet OFAC and EU still have this entity listed.

Tuesday, April 6th - France removed eleven names from the French list of sanctions. Two of them were reflections of name removals by the UN and the rest were related to France unilateral sanctions. (Here)

- OFAC added three individuals and two entities to the SDN list under the Kingpin Act. (Here, press release)

- United States Department of State imposed travel bans on a Paraguayan representative and his wife using section 7031(c) of the Department of State, Foreign Operations, and Related Programs Appropriations Act, 2021. (Here)

- Charges were unsealed against an individual who allegedly exported cosmetic products to Iran. (Here)

Wednesday, April 7th

- OFAC added four individuals and two entities involved in human smuggling to the United States pursuant to its Transnational Criminal Organization program. (Here, press release) If you want to know more about this program, please click here.

Thursday, April 8th

- OFAC added Myanma Gems Enterprise to its SDN list pursuant to the Burma program. (Here, Treasury press release, Dept. of State press release)

- BIS added seven Chinese entities to the Entity List. (Here) These entities, as stated by the Department of Commerce, are involved in building supercomputers used by China’s military actors, its destabilizing military modernization efforts, and/or weapons of mass destruction (WMD) programs.

Friday, April 9th

- No major development on this day.

Recommendations of the week

- This week I would like to recommend the recently updated version of "Iran Sanctions" published by Congressional Research Service. It is a great source of information and gives you context about many rounds of sanctions against Iran. (Here)


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