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Last week's major developments in sanctions - December 11th to December 15th, 2023

Monday, December 11
  • On International Anti-Corruption Day:

  • OFAC imposed asset-freezing sanctions against two former Afghan government officials and 44 associated entities for transnational corruption.  (Here, Department of Treasury press release)

  • The U.S. State Department imposed visa restrictions, (a type of sanctions) on over 30 individuals for their involvement in corruption. (Department of State press statement, Department of State fact sheet)

  • The U.S. Department of State imposed visa restrictions (a type of sanction) on nearly 300 individuals, including over 100 members of the Guatemalan Congress for their involvement in anti-democratic action in Guatemala. (Department of State press statement)

  • The Department of Justice, Department of Commerce’s Bureau of Industry and Security (BIS), Department of Homeland Security’s Homeland Security Investigations (“HSI”), Department of State’s Directorate of Defense Trade Controls (“DDTC”), and OFAC, published “Quint-Seal Compliance Note - Know Your Cargo” detailing sanctions evasion techniques and civil enforcement actions in response to violations of sanctions and export controls.  (Quint-Seal Compliance Note)

  • On a busy day on the EU sanctions front, the EU Council:

  • Imposed asset-freezing sanctions against six individuals and five entities, under the EU sanctions regime against Russia, for their involvement in Iran’s development of unmanned aerial vehicles used in Russia's war against Ukraine; (Here, European Council press release)

  • Renewed the Mali sanctions regime for one year, through December 14, 2024; (Here, EU Council press release)

  • Imposed asset-freezing sanctions on four individuals and two entities for their involvement in the overthrow of Myanmar’s democratically elected government; and,  (Here)

  • Renewed the Democratic Republic of the Congo sanctions regime through December 12, 2024. (Here)

  • The UK government announced that it is setting up a new office, the Office of Trade Sanctions Implementation (“OTSI”), responsible for the implementation of trade sanctions of the United Kingdom. (Here) 


Tuesday, December 12
  • OFAC announced a settlement with CoinList Markets LLC for violations of Russia/Ukraine Sanctions for over $1.2 million. (Here)

  • The United States imposed additional sanctions regarding Russia’s war effort and other harmful activities. Specifically,  

  • OFAC imposed asset-freezing sanctions on 23 individuals and over 100 entities. (Here, Department of Treasury press release)  Concurrently, OFAC issued two Russia-related General Licenses related to the newly designated targets. (General License NO. 79, General License NO. 80)

  • The U.S. Department of State, which is in charge of designations under some sections of EO 14024, designated over 100 individuals and entities, and as such they are subject to asset-freezing sanctions. (Here)

  • The U.S. Department of State imposed visa restrictions (a type of sanction) on individuals for their involvement in undermining democracy in Honduras by carrying out and encouraging violence. (Here)


Wednesday, December 13

Thursday, December 14
  • France imposed asset-freezing sanctions on two individuals under its counter-terrorism sanctions regime. (Here

  • OFSI published its 2022 to 2023 Annual Review. (Here

  • The UK announced a new round of sanctions against Russia. The new sanctions, among other things, banned the import of diamonds from Russia. (The Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2023, the Russia (Sanctions) (EU Exit) (Amendment) (No. 5) Regulations 2023, press release

  • OFSI issued General License INT/2023/4078352 which would allow Payment Processing related to certain newly designated Russian banks through December 22, 2023. (Here)

  • OFSI rolled out a new Iran sanctions program against Iran which is an expanded version of what it had against Iran for Human Rights concerns.  The new regime has several new designation grounds and introduced new trade restrictions. (Here, and the relevant press release

  • Immediately after the new Iran sanctions came into force, OFSI designated seven individuals under this regime, including the head of Iran IRGC Quds Force, and one entity. (Here)

  • In line with OFSI, OFAC imposed asset-freezing sanctions on one of the officials of the IRGC Quds Force (Here, Department of Treasury press release)

  • OFAC also imposed asset-freezing sanctions on one entity, Malas Mañas, a transnational criminal organization, and two individuals in Malas Mañas’s support network, for their involvement in human smuggling and narcotics trafficking. (Here, Department of Treasury press release)

  • A former Special Agent in Charge of the FBI Counterintelligence Division, Charles McGonigal, was found guilty of conspiring to violate the International Emergency Economic Powers Act and to commit money laundering to Oleg Deripaska, a Russian oligarch who is subject to asset freezing sanctions. While working for the FBI, McGonigal investigated Deripaska and Russian oligarchs for sanctions violations. He was sentenced to jail for 50 months and was ordered to pay a $40,000 fine. (Department of Justice press release)


Friday, December 15
  • OFSI imposed asset-freezing sanctions against Novikombank under its Russia sanctions regime. (Here)

  • OFSI published an Iran Sanctions guidance. (Here)

  • OFSI amended General License INT/2023/3626884 to also permit activity that would otherwise breach the prohibitions in Regulation 17A of the Russia Regulations. (Here)


Recommendations of the Week
  • The Department of the Treasury released a blog post discussing the impact of sanctions and export controls against Russia. (Here)

  • The U.S. Government Accountability Office published a new study on economic sanctions and digital assets. You can check it out here.

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