Monday, August 28
OFAC published its second informational video: Episode 2: Blocking and Non-Blocking Sanctions (I love these videos! Kudos to OFAC for creating them.)
Tuesday, August 29
There was no major development on this date.
Wednesday, August 30
There was no major development on this date.
Thursday, August 31
OFSI for the first time used the authority under 149(3) of the Policing and Crime Act 2017 by publishing an enforcement action that does not involve a monetary penalty. The Disclosure Notice pertains to a violation of Russia sanctions by Wise Payments Limited. The facts of the case are very interesting and demonstrate the importance of speedy action upon new designations as well as the implementation of controls on products and services provided to customers against whom there is an outstanding hit. (Here)
OFSI has updated Section 10 of its Enforcement and Monetary Penalty Guidance to provide further details on how it assesses the severity of breaches.
OFAC imposed asset-freezing sanctions on two individuals and one entity under its North Korea sanctions program. (Here, the Department of the Treasury's press release, and the Department of State's press release)
At the request of the United States, Cyprus arrested a Geman-Russian citizen who is suspected of participation in an ongoing scheme to procure U.S.-sourced microelectronics subject to U.S. export controls on behalf of a Russia-based supplier of critical electronics components for manufacturers supplying weaponry and other equipment to the Russian military. (Here)
BIS issued a Temporary Denial Order suspending the export privileges of three individuals and four companies that are part of a Russia-based illicit procurement network that supplies the Russian military. (Here, and press release)
Friday, September 1
The UK's Secretary of State issued a general trade license that authorizes the provision of certain direct or indirect legal advisory services that were otherwise prohibited under the controversial regulation 54D of the Russia (Sanctions) (EU Exit) Regulations 2019 to any person. The new general license allows UK persons to provide sanctions-related advice. Of note is that the general license has reporting requirements. (Here)
OFAC imposed asset-freezing sanctions on four individuals and one entity under its Russia sanctions program. (Here, the Department of the Treasury's press release, and the Department of State's press release)
Recommendations of the Week
Read this Policy Alert from Steptoe that covers all the recent developments in the Tornado Cash case.
Debevoise & Plimpton published a "Guide to US, UK, and EU Sanctions and Export Controls on Russia and Belarus." I found it very comprehensive and useful, so sharing it with everyone.
I, along with other practitioners at K2 Integrity and DOLFIN Academy, will start a "world tour" on sanctions against Russia in collaboration with the United States Department of State. Our first stops are Yerevan and Tbilisi. Next, we will go to Kazakhstan and Azerbaijan. More to come on this but, for now, if you are in any of those places, we would love to meet you and potentially have you at our training sessions. For more information, you can email me at afadavi@k2integrity.com.