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Last week's major developments in sanctions - December 19th to December 23rd, 2022

Monday, December 19

  • This blissfully slow week started with a couple of designations in France. France added the names of six individuals to its list of sanctions targets under the country's counter-terrorism sanctions program. (Here)

  • OFAC published Illicit Drug Trade Sanctions Regulations (31 C.F.R. 599) to implement Executive Order 14059 of December 15, 2021.

Tuesday, December 20

  • The UK government added a new ground for license request consideration under its Russia sanctions program. Accordingly, the UK government will consider requests for licenses for "the export, making available, supply, or delivery of Russia’s vulnerable goods for medical and pharmaceutical purposes, provided that this is for the benefit of the civilian population." (Here)

  • Following the adoption of the UNSCR 2664 (2022) on December 9, 2022, which established humanitarian carveouts under various UN sanctions programs, the United States issued several general licenses and amended some across different sanctions programs. The new general licenses are all codified in relevant regulations. OFAC has tried to use the same language to the extent possible across various sanctions programs. (Here, the Department of the Treasury's press release, the Department of State's press release) OFAC published four FAQs to explain this action, notably FAQ 1108 which states none of the new licenses restrict the scope of any existing exemptions or OFAC authorizations for humanitarian activities.

  • OFAC also updated a regulatory interpretation in several sanctions programs’ regulations to explain that the property and interests of property of an entity are blocked if one or more blocked persons own, whether individually or in the aggregate, directly or indirectly, a 50 percent or greater interest in the entity. This was known before and the OFAC's move was rather administrative. (Here)

Wednesday, December 21

  • France added five individuals to its list of sanctions targets under the country's counter-terrorism sanctions program. (Here)

  • OFAC imposed blocking sanctions on five high-rand officials in Iran, and one entity, all of whom are involved in ongoing violation of human rights in Iran. (Here, the Department of the Treasury's press release, the Department of State's press release)

  • In an export control-related development, BIS imposed additional restrictions on the Wagner group. As part of today's action, BIS designated the group as a Russian or Belarusian military end-user. (Here)

Thursday, December 22

  • Following the judgment of the Court of Justice of the EU of 28 September 2022, Libyan African Investment Company (Laico) v Council, the Council removed LIACO from the list of sanctions targets under the Libyan sanctions regime of the EU. (Here)

  • The United States Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) issued a Financial Trend Analysis on the financial activity of Russian oligarchs. The report focuses on trends seen in SARs filed between March 2022 and October 2022 involving Russian oligarchs, high-ranking officials, and sanctioned individuals. (Here)

  • The United States Department of State designated 10 Russian naval entities for operating or having operated in both the defense and related materiel sector and the marine sector of the Russian Federation economy or operating or having operated in the marine sector of the Russian Federation economy. (Here, the Department of State's press release)

Friday, December 23

  • There was no major development on this day.

The Wish of the Week

  • For those of you who are celebrating festivities at this time of the year, I wish you all the best. This is the last update of this year and I would like to thank you all for following Sanctions Experts, your kind words, and your positive energy throughout the year. It was a hectic year in sanctions, and I hope you can all get some very well-deserved rest.

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