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Last week's major developments in sanctions - August 7th to August 11th, 2023

Monday, August 7

  • France imposed asset-freezing sanctions on an individual pursuant to the country's autonomous counter-terrorism sanctions regime. (Here)

Tuesday, August 8

  • OFSI imposed asset-freezing sanctions against six entities under its Belarus sanctions regime. (Here and press release)

  • OFSI also imposed asset-freezing sanctions against ten individuals and nine entities under its Russia sanctions regime. (Here, and press release) Many of the designated entities are located in third countries and are accused of supporting Russia by exporting certain goods to Russia.

  • OFAC published a new Compliance Communiqué about the provision of humanitarian assistance to Syria. The Communiqué gathered different authorizations under the Syria sanctions program in one place and includes a few questions and answers. One that I found useful is one about the use of crowdfunding platforms. (Here) Concurrently, OFAC amended one FAQ 937, which relates to Syria.

Wednesday, August 9

  • OFAC imposed asset-freezing sanctions on three Sinaloa Cartel members involved in the illicit trafficking of fentanyl and other deadly drugs. (Here, the Department of the Treasury's press release, and the Department of State's press release)

  • OFAC imposed asset-freezing sanctions on eight individuals and five entities under its Belarus sanctions program. OFAC also identified one aircraft as the property of a blocked person. OFAC issued two wind-down general licenses to allow certain activities related to two of the recently designated entities. Additionally, the Department of State imposed visa restrictions on 101 regime officials and their affiliates for undermining or harming democratic institutions in Belarus, including several judges responsible for issuing politically-motivated sentences against Belarusians for exercising their fundamental freedoms. (Here, the Department of the Treasury's press release, and the Department of State's press release)

  • In a non-sanction-related action, President Biden issued a new Executive Order on outbound investment aimed at addressing concerns related to China’s advancement in sensitive technologies critical for military, intelligence, surveillance, or cyber-enabled capabilities. To know more, please check out this client alert published by Akin's team.

Thursday, August 10

Friday, August 11

  • 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)

Recommendation of the Week

  • Read this Policy Alert from K2 Integrity about the DOJ, BIS, and OFAC Tri-Seal Compliance Note on VSDs. The Alert lists a number of considerations for companies that are assessing whether to file VSDs or not. Please let me know if you have any questions or if you need help by sending an email to afadavi@k2integrity.com

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