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Last week's major developments in sanctions - Feb. 22nd to Feb. 26th, 2021

Monday, February 22nd:

- This week started with the addition of 19 Venezuelan officials to the Venezuelan regime of the EU (Council Regulation (EU) 2017/2063). Now there are 55 targets under this European regime. It is still far from the broader sanctions imposed by the United States against Venezuela.

- Following the removal of 2 individuals by the Security Council ISIL (Da’esh) and Al-Qaida Sanctions Committee on Feb.19, both the U.K. (here) and France removed those two names on Monday. It was followed by the removal of those two names by the EU Commission on Friday. (Here) Interestingly, those two names are still listed as SDNs (as of the date of the publication of this update).

- OFAC added the [PEESA] tag to two already listed entries on the SDN list. (PEESA stands for Protecting Europe’s 5 Energy Security Act) The new tags did not change the sanction measures in place against the targets as they were already subjected to the blocking sanctions under CAATSA. (It may, however, complicate removal of sanctions, in case that would ever happen.) The tag additions took place following the submission of a report of the Department of State to the Congress on Friday. The report also identified 15 entities that have engaged in good-faith efforts to wind down activities related to the Nord Stream 2 project. (Here)

- OFAC designated two individuals to its recent Burma program. (Here) (Treasury Press release) (Department of State press release)

Tuesday, February 23rd: - There was no major development on this day.

Wednesday, February 24th:

- There was no major development on this day.

Thursday, February 25th:

- Financial Action Task Force (FATF) concluded its 3-day long plenary meeting on Thursday. One of the most important outcomes of this meeting was that the FATF agreed to release an update to the FATF guidance for virtual assets and VASPs for public consultation. (Click here to see the outcomes)

- OFSI added five individuals and one entity to its sanctions list pursuant to its Burma regime. (Here)

- The United States' Department of State, imposed travel restrictions on former Prosecutor General Dobroslav Trnka of the Slovak Republic due to his involvement in significant corruption. The travel restriction was also imposed against Dobroslav Trnka son, Jakub Trnka. The authority pursuant to which these restrictions were imposed is section 7031(c) of the Department of State, Foreign Operations, and Related Programs Appropriations Act, 2020. (Here)

- EU Council prolonged its Belarus sanctions regime for another year. (Here)

- The United Nation Security Council extended sanctions imposed against Yemen and added Sultan Saleh Aida Aida Zabin is the director of the Criminal Investigation Department (CID) in Sanaa to its list of targets. (Here)

Friday, February 26th:

- The Security Council Committee pursuant to resolution 751 (1992) concerning Somalia added three individual to its sanctions list. (Here)

- OFAC designated Ahmad Hassan Mohammed al Asiri, Saudi Arabia’s former Deputy Head of General Intelligence Presidency, and Saudi Arabia’s Rapid Intervention Force under its Global Magnitsky program in connection with the murder of journalist Jamal Khashoggi. (Here) (Treasury press release) In parallel, the Department of State imposed visa restrictions pursuant section 212(a)(3)(C) of the Immigration and Nationality Act. These visa bans are part of a new policy which was announced concurrently called "Khashoggi Ban." The Khashoggi Ban allows the State Department to impose visa restrictions on individuals who, acting on behalf of a foreign government, are believed to have been directly engaged in serious, extraterritorial counter-dissident activities, including those that suppress, harass, surveil, threaten, or harm journalists, activists, or other persons perceived to be dissidents for their work, or who engage in such activities with respect to the families or other close associates of such persons. (Here)

Recommendations of the week:

- This week I would like to recommend to you an investigative report published by The New York Times about an unusual Specific License issued by OFAC on January 15, 2021 (5 days before the Biden administration took the office). The broad Specific License authorized almost all transactions related to Dan Gertler, an SDN under the Global Magnitsky program. (Here) I had also recommended an earlier version of this investigation by NYT in one of my previous weekly updates. (Here)


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