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Last week's major developments in sanctions - April 29th, 2024, to May 3rd, 2024

Monday, April 29
  • OFSI issued a new general license for legal services under its Russia and Belarus sanctions regime. The new license replaces the previous one and slightly differs from the previous version. (Here)

  • BIS issued a final rule that adds a new license exception for certain medical devices destined for Russia and Belarus. (Here)

  • OFAC issued General License 8I under its Russia sanctions program which replaced General License 8H, which was valid till May 1, 2024. The new license is valid through November 1, 2024. (Here)

Tuesday, April 30
  • OFSI imposed asset-freezing sanctions against three individuals under its global anti-corruption sanctions regime. (Here, press release)

  • OFSI extended General License INT/2023/3749168 (Israel and the Occupied Palestinian Territories humanitarian activity) and is now valid through May 14, 2025. (Here)

Wednesday, May 1
  • The UK's Export Control Joint Unit announced that the HM Revenue and Customs issued seven settlements between January and March 2024 in relation to unlicensed exports of military or dual-use goods. (Here)

  • In a welcome move, OFSI published a dedicated FAQ page. As of the date of this publication, there are 91 questions on it. (Here)

  • The Department of State published a proposed rule in the Federal Register that, if finalized, would create an exemption for certain exports, reexports, retransfers, or temporary imports of defense articles or defense services, or certain brokering activities between or among authorized users within AUKUS partners (i.e., Australia, the United Kingdom, and the United States). (Here, press release)

  • OFAC and the State Department imposed blocking sanctions against 298 individuals, entities, and vessels for helping the Russian military-industrial base evade sanctions and export restrictions. (OFAC designation information, the Department of the Treasury's press release, the Department of State's press release, additional Department of State's press release) I broke down the designations by location of targets:

Thursday, May 2
  • OFSI updated its Financial sanctions enforcement and monetary penalties guidance. The updated version communicates that OFSI will now always apply the most recent iteration of its Enforcement guidance to cases. The guidance provides further explanation on how OFSI applies and splits the case factors that OFSI uses to assess suspected breaches of financial sanctions. It also introduces two new distinct case factors, “Knowledge, intention and reasonable cause to suspect” and “Cooperation” that were previously included more generally in the guidance. (Here)

  • OFAC imposed blocking sanctions on five individuals and two entities under its global counter-terrorism sanctions program for helping U.S.-designated Hizballah money exchanger. (OFAC designation information, the Department of the Treasury's press release, the Department of State's press release)

Friday, May 3
  • France imposed asset-freezing sanctions against one individual under its autonomous counter-terrorism sanctions regime. (Here)

  • OFSI imposed asset-freezing sanctions against four individuals and two entities under its global anti-corruption sanctions regime for inciting and perpetrating violence against Palestinian communities in the West Bank. (Here, press release)

Recommendation for the week
  • For this week I have two webinars to recommend:

    • Sanctions Evasion and Secondary Risk: Managing Global Compliance (Register here)

    • Tackling Proliferation Financing Challenges | Latest Red Flags, Emerging Trends & Case Studies (Register here)


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