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Last week's major developments in sanctions - Dec. 6th to Dec. 10th, 2021

Monday, December 6th

- This week started the EU Council's Decision to prolong its Human Rights Sanctions regime through December 8, 2022. (Decision, press release)


- OFAC added one individual and 12 entities to the SDN list under its Global Magnitsky program. The added individual, Alain Mukonda, allegedly provided support to another sanctioned person Dan Gertler. This addition to the SDN list is a great example of the so-called derivative sanctions. (Here, the Department of Treasury's press release, the Department of State press release)


Tuesday, December 7th - The EU Council removed one individual, Oleksandr Viktorovych Klymenko, from its sanctions lists. (Decision)


- OFAC added several individuals and entities for their roles in repressions of protests in Iran and Syria. OFAC used a number of different authorities (Executive Orders 13818, 13553, 13572, and CAATSA) which proves the complexity of sanctions imposed over years. (Here, the Department of Treasury's press release, the Department of State press release)


- The U.S. DoJ successfully forfeited Iranian arms and oil which were seized previously. (Press release)

Wednesday, December 8th

- OFAC added 16 individuals and 24 entities to the SDN list under the GLOMAG program. (Here, the Department of Treasury's press release, the Department of State press release)


- OFAC announced a settlement agreement with a natural U.S. person in the amount of $133,860. The apparent violations related to four transactions the U.S. person was involved in where an Iran-based company sold some Iranian-origin goods to another party in a third country. Interestingly, the U.S. person had applied for a specific license and it was denied. The U.S. person engaged in the transactions regardless of the denial. (Here) This enforcement action was a reminder that sanctions are not only for entities.


- The UNSC 1518 sanctions committee (Iraq-related) removed two individuals from its list of sanctions targets. (Here)


Thursday, December 9th

- The EU Council prolonged the Democratic Republic of the Congo's sanctions regime for another year. (Decision, press release)


- On International Anti-Corruption Day, OFAC added seven individuals and eight entities to its SDN list under the GLOMAG program. (Here, press release) Furthermore, the Department of State imposed travel restrictions (a type of sanctions) on nine individuals and their immediate family members for their roles in corruption under Section 7031(c) of the Department of State, Foreign Operations, and Related Programs Appropriations Act, 2021. (Here)


- The United States sent a delegation to the UAE led by OFAC Director, Andrea Gacki, to discuss the importance of compliance with the sanctions against Iran. (Here, press release)


- In an export control related development, the Bureau of Industry and Security (BIS) amends the Export Administration Regulations (EAR) to apply more restrictive treatment to exports and reexports to, and transfers within, Cambodia of items subject to the EAR. (Here)


Friday, December 10th

- OFSI added one individual under its Global Human Rights Sanctions regime and added four entities under its Myanmar Sanctions regime to the UK's list of financial sanctions targets. (Global Human Rights Notice, Myanmar Notice)


- The Department of State imposed travel restrictions against additional 12 individuals and their immediate family members under Section 7031(c) of the Department of State, Foreign Operations, and Related Programs Appropriation Act, 2021. (Here)


- More human rights oriented sanctions! OFAC added 15 individuals and 10 entities to the SDN list, and it added one entity to NS-CMIC list. (Here, press release)


- OFAC issued a highly needed general license which allows noncommercial, personal remittances to Afghanistan even if it involves a sanctioned person in the transactions. OFAC also amended FAQ 931, and published FAQ 949. (Here)


Recommendation of the week

- What a week! A lot of actions taken by the western governments to fight corruption and human right violations. Related to these actions, the U.S. published its strategy on countering corruption. (Here)

 

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