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Last week's major developments in sanctions - December 26th to December 30th, 2022

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.


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