Monday, December 26
There was no major development on this day.
Tuesday, December 27
There was no major development on this day.
Wednesday, December 28
The UK imposed blocking sanctions on Jimmy Chérizier under the UK's recently-implemented Haiti sanctions regime. He was added to the UN sanctions list in late October. The United States imposed blocking sanctions on him two years ago in Dec. 2020.
Thursday, December 29
There was no major development on this day.
Friday, December 30
Kudos to OFAC for working till the very last day of 2022. On this last day, OFAC issued a "Preliminary Guidance on Implementation of the Price Cap Policy" stating that the price cap mechanism for petroleum products will be similar to that of Russian crude. The expected date for implementation is February 5, 2023, and OFAC will issue more guidance by then. (Here)
OFAC also announced a settlement agreement with a Danish Company, Danfoss A/S. The settlement was a great reminder that the U.S. sanctions reach is extensive. In this matter, a UAE subsidiary of Danfoss had its clients in Iran, Sudan, and Syria pay to the subsidiary account held with a UAE branch of a U.S. bank. An interesting point in the announcement was that OFAC mentioned they were already in possession of the information related to the apparent violations and as such did not give credit to Danfoss for its voluntary self-disclosure.
The Recommendation of the Week
The EU Commission has been publishing numerous FAQs about the EU restrictive measures (aka. sanctions). If you have not already seen them you can find them all on this page: Frequently asked questions concerning sanctions adopted following Russia’s military aggression against Ukraine and Belarus' involvement in it