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Last week's major developments in sanctions - August 1st to August 5th, 2022

Monday, August 1

Tuesday, August 2

  • The U.S. Department of Commerce Bureau of Industry and Security (BIS) announced an enforcement action against an individual located in Arizona for exporting items subject to EAR to Mexico without first obtaining the appropriate license. As a result of this action, the individual in question will be subject to a two-year suspended denial of his export privileges. He must also complete a twelve-month internal audit of his company’s export controls compliance program and an export compliance training. (Here)

  • The UK's OFSI added two individuals to its list of sanctions targets and removed one. (Here)

  • The U.S. Department of State and the Department of Treasury imposed blocking sanctions against several entities and individuals under the U.S. Russia sanctions program. OFAC issued three general licenses allowing certain wind down activities related to a number of entities designated on this day. (Here, Treasury's press release, State's press release) The three general licenses were later updated on the next day since OFAC had forgotten to include "leasing" in those. (Here)

  • OFAC issued general licenses General License 40A, General License 43A which replaced general licenses 40 and 43 respectively. (Here)

  • BIS identified 25 aircraft that are foreign-made but still subject to EAR because they pass the de minimis test. The identification of these aircrafts are important because it put the public on notice that by engaging in certain activities related to those aircraft they may violate General Prohibition Ten. (Here)

  • BIS issued a Temporary Denial Order (TDO) against Venezuela-based cargo airline Empresa de Transporte Aéreocargo del Sur, S.A. because it acquired an aircraft which was subject to EAR from Mahan Air which itself had been subject of a TDO. Therefore, the transaction was in breach of the initial TDO. The Venezuelan airline also violated EAR by flying to Iran and Russia. In addition to the new TDO, the DoJ requested the Argentinian authorities to seize the aircraft because both Mahan and Empresa violated the U.S. laws. (BIS action, DoJ action) This is a great example of how U.S. nexus works under U.S. export control laws which is different from the notion of nexus in financial sanctions.

Wednesday, August 3

  • There was no major development on this day.

Thursday, August 4

  • The EU Council imposed blocking sanctions on pro-Russian former President of Ukraine Viktor Fedorovych Yanukovych and his son Oleksandr Viktorovych Yanukovych. (Here, press release)

Friday, August 5

  • There was no major development on this day.

Recommendation of the week

  • We've been hearing about governments' efforts in seizing digital assets. In many cases, they succeed. Have you wondered how governments can seize such assets? If so, here is a short article by MIT Technology Review about it.

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