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Last week's major developments in sanctions - August 22nd to August 26th, 2022

Monday, August 22

  • OFSI issued two new General licenses and amended General License INT/2022/1280876 to permit payments involving the Guernsey subsidiary of VTB, and VTB Bank (Europe) SE based in Germany. The two new General licenses are:

    1. General License INT/2022/2104808 allows banks to take payment of bank fees from frozen accounts.

    2. General License INT/2022/1845976 allow Crown Servants (an individual holding office or employment under the Crown), Contractors, & their Family Members to carry out activities in their personal capacity which would otherwise be prohibited. (This is for those who work for the UK's government and are in Russia.)

Tuesday, August 23

  • OFSI removed Mikhail Razvozhayev, who used to be governor of Sebastopol in 2019, from the list of sanctions targets in the UK. (Here)

Wednesday, August 24

  • OFSI designated three entities in Myanmar that are allegedly linked to the country's military. (Here, press release)

Thursday, August 25

  • BIS published a summary of actions it has taken since Russia invaded Ukraine six months ago. (Here)

Friday, August 26

  • OFAC issued General License M2 under its Iran program authorizing the exportation of certain graduate level educational services and software to Iran till September 1, 2021. General License M2 replaced General License M1 which was issued in the context of Covid 19 pandemic and the impact it had on the Iranian students enrolled in the U.S. universities. (Here)

Recommendation of the week

  • Last week the Wolfsberg Group published a guidance paper on Requests For Information (RFIs) as used in the anti-money laundering transaction monitoring process. Take a look at it here.


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