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Last week's major developments in sanctions - Feb. 8th to Feb. 12th, 2021

Monday, February 8th:

- EU official journal published the Feb. 5th decision of the Council updating the listings under one of anti-terrorism programs of the EU (Common Position 2001/931/CFSP). Based on this sanctions regime, names of the targeted individuals and entities should be updated every six months to ensure that the grounds for listing still exist. (Here)

Tuesday, February 9th: - No major development on this day.

Wednesday, February 10th:

- The United States' President announced that he approved the new sanctions against the military leaders who directed the coup, their business interests, as well as close family members. (Here) Please note that at that point he had not issued an Executive Order.

Thursday, February 11th:

- The United States' President issued a new Executive Order imposing sanctions against Burma. The President laid the ground for asset freezing sanctions as well as travel bans. Among those targeted by these new sanctions is the Government of Burma. (Here) It was followed by the addition of 8 individuals and 3 entities to the SDN list with the new tag of [BURMA-EO]. The designation of two individuals who were already on the SDN list under the Global Magnistky program were modified to reflect their addition pursuant to the new Burma sanctions program. (Treasury's press release) (Dept. of State's press release)

- The Bureau of Industry and Security of the Department of Commerce, announced that "[e]ffective immediately, BIS will apply a presumption of denial for items requiring a license for export and reexport to these select Burmese government departments and agencies. In addition, BIS is revoking certain previously issued licenses to these departments and agencies which have not been fully utilized. BIS also will suspend certain license exceptions previously available to Burma as a result of its current Country Group placement under the Export Administration Regulations (EAR), including Shipments to Country Group B countries (GBS) and Technology and Software under restriction (TSR)." (Here)

- The United States' President submitted a notice to the Congress to extend the national emergency declared in 2011 regarding the situation in Libya. (Here)

Friday, February 12th:

- Secretary of the State announced that effective Feb. 16, 2021, the recent designation of Ansarallah as an FTO and SDGT will be revoked. (Here) Ansarallah was one of the last-minutes actions of the previous administration which raised concerns about the flow of humanitarian aid to the people of Yemen.

Recommendations of the week:

- This week I would like to recommend to you a great webinar presented by Steptoe and Johnson about United States v. Ali Sadr Hashemi Nejad, a sanctions-related case which was brought in SDNY last year. Apart from the very interesting facts of the case, there are thought-provoking points about the somehow blurry line between sanctions compliance and sanctions evasion at the end of the webinar. Also, pay attention to the discussion about the U.S. nexus starting at 40:30. Here is the link to the recording of the webinar:


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