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Last week's major developments in sanctions - Dec. 20th to Dec. 24th, 2021

Monday, December 20th

- France published the name of four newly-designated individuals pursuant to its counter-terrorism sanctions regime. (Here)

- Following the submission of the report pursuant to section 5(a) of the Hong Kong Autonomy Act by the Department of State, OFAC made some changes to the SDN list. Notably, it added the following to a five entries: "Secondary sanctions risk: pursuant to the Hong Kong Autonomy Act of 2020 - Public Law 116-149." (Here) These four names used to be subject to secondary sanctions but OFAC had removed that. (Here)

Tuesday, December 21st - The Australian Autonomous Sanctions Amendment (Magnitsky-style and Other Thematic Sanctions) Regulations 2021 came into force on December 21, 2021. It expands the designation powers of the Aussie Government in designation of those violating Human Rights, Corrupt persons and some Cyber Criminals. (Here)

Wednesday, December 22nd

- The United Nations Security Council added two individuals to its sanctions lists; one pursuant to its counter-terrorism sanctions regime and the other pursuant to Central African Republic sanctions regime.

- The United Nations Security Council decided that humanitarian assistance along with other activities that support basic human needs in Afghanistan are not a violation of a provision in resolution 2255 (2015) concerning individuals and entities associated with the Taliban in constituting a threat to the peace, stability and security of Afghanistan. (Here)

- The U.S. Department of State imposed travel bans (a type of sanction) against two former officials in Malt (and some of their family members) for their roles in corrupt activities under Section 7031(c) of the Department of State, Foreign Operations, and Related Programs Appropriations Act, 2021. (Here)

- OFAC added two individuals in Brazil to the SDN list because of their relationship with Al-Qaida. (Here, the Department of Treasury's press release, the Department of State's press release)

- Following the UN's action authorizing some humanitarian activities related to Afghanistan, OFAC issued:

In short, the new authorizations are similar to those that are in place in the U.S. comprehensive sanctions programs even though Afghanistan is not one of them. (The Department of Treasury's press release, the Department of State's press release)

Thursday, December 23rd

- OFAC amended its WMD regulations. (Here)

- OFAC published a settlement agreement withTD Bank N.A. involving two cases. One of them was related to bank accounts of individuals working for the North Korean mission at the UN HQ in New York, and the other one was related to an account opened for a SDN. (Here)

Friday, December 24th

- No major development of this day.

Recommendation of the week

- Check out the story about how Sri Lanka decided to pay off its debt to Iran: Sri Lanka to settle $251 mln oil import dues to Iran by bartering tea

This one is interesting because the Sri Lankan Government is paying Iran for the oil it had received. Oil revenues is a vital source of revenue for the Iranian Government and is what the U.S government has tried to limit. The Sri Lankan party argues that there is no U.S. nexus, and in addition to that selling tea to Iran would be covered by the existing general licenses so the risk of being designated is low. Whether the U.S. government agrees or not remains to be seen. This way of settling the outstanding debts is not a new way for the Iranians to get access to their blocked funds.

Happy holidays and enjoy the festivities.


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