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Last week's major developments in sanctions - Feb. 1st to Feb. 5, 2021

Monday, February 1st:

- France added ten individuals to its national list of asset freezing measures per section L. 562-2 of France Monetary and Finance Code. (Here) Several of the recently-added individuals were added to the list at some point in the past by the France Ministry of the Economy and Finance.

- OFSI added four high-ranking officials in Zimbabwe to its list. Three of these newly-listed individuals were already listed by OFAC. (Here)

Tuesday, February 2nd: - U.S. Dept. of State held a press conference about Burma in which the topic of sanctions against Burma and its military officials were raised several times. (Here)

- OFAC issued General License 30A which slightly expanded the scope of the previous General License 30 by additionally authorizing transactions involving the Instituto Nacional de los Espacios Acuaticos (INEA), an SDN, that are ordinarily incident and necessary to operations or use of ports and airports in Venezuela. (Here)

- France made some changes to it asset freezing authorities in order to be able to freeze the assets of those listed by the UNSC sanctions regimes immediately. (Here)

Wednesday, February 3rd:

- DOJ filed a complaint in U.S. District Court for the District of Columbia alleging that all oil aboard a Liberian-flagged vessel is subject to forfeiture based on U.S. terrorism forfeiture laws as it belongs to IRGC. (Here)

Thursday, February 4th:

- EU Commission delisted Iraqi State Enterprise for Foodstuffs Trading. (Here)

Friday, February 5th:

- France added one individual to its national sanctions lists. (Here)

- The EU Council renewed the so-called EU terrorist list, which sets out persons, groups and entities subject to restrictive measures with a view to combating terrorism. (Here) The authority for this sanctions regime is Council Regulation (EC) No 2580/2001 and the relevant Council decision. For more about EU counter-terrorism sanctions please check here.

Recommendations of the week:

- This week I would like to bring your attention to an action recently taken by the Central Bank of U.A.E. (CBUAE). CBUAE imposed penalties on 11 banks in U.A.E. for the banks’ failures to achieve appropriate levels of compliance regarding their AML & Sanctions Compliance Frameworks as at the end of 2019. To see the official announcement click here. To see a brief note about the authority of CBUAE to impose monetary penalties pursuant to UAE AML Law, which I found informative, click here.


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