Last week's major developments in sanctions - February 20th to February 24th, 2023

Monday, February 20

• The EU Council imposed blocking sanctions on 32 officials and two entities in Iran, all of which are responsible and involved in human rights violations. (Here, press release)

• The EU Council imposed blocking sanctions on nine individuals and seven entities for their roles in human rights violations and threats to peace, security, and stability in Myanmar. (Here, press release)

• The United Kingdom imposed blocking sanctions on eight senior Iranian figures responsible for repressing the people of Iran. (Here, press release)

Tuesday, February 21

• The G7 Foreign Ministers issued a statement in which they reiterated that their countries will impose further economic costs (aka sanctions) on Russia, and on individuals and entities – inside and outside of Russia – that provide political or economic support to Russia in its war of aggression against Ukraine. (Here)

• OFAC issued a very welcomed communique providing guidance to the public on how to provide assistance related to earthquake relief to Syria while complying with OFAC sanctions. (Here)

Wednesday, February 22

• As the fentanyl issue persists in the United States the Department of the Treasury imposes blocking sanctions on targets. This time, OFAC imposed blocking sanctions on six individuals and six entities under the country's counter-narcotics sanctions program. (Here, the Department of the Treasury press release, the Department of State press release)

Thursday, February 23

• France imposed blocking sanctions on four individuals on the country's counter-terrorism autonomous sanctions regime. (Here)

• The EU Council amended its Syria sanctions regime to streamline the flow of aid to Syria. The new amendment introduced a new paragraph (paragraph 1) to article 28a of Decision 2013/255/CFSP and waived the need for humanitarian organizations to seek prior permission from EU member states national competent authorities to make transfers or provide goods and services intended for humanitarian purposes to listed persons and entities. (Here, press release)

Friday, February 24

• This day was all about sanctions (or other measures) against Russia:

  1. Australia started the day by imposing additional blocking sanctions on several individuals and entities (here, press release);

  2. The United Kingdom

     1. Imposed additional blocking sanctions on several individuals, including several Russian elites (CEOs close to Putin), and entities including four banks (here). Following this, OFSI amended three of the existing general licenses;

     2. Expanded its existing export bans to include a ban on the exportation of all products found used by Russia on the battlefield (here);

     3. An import ban on 140 additional goods including iron and steel products processed in third countries (here); and

     4. Finally, will be extending existing measures against Crimea, and non-government-controlled territory in Donetsk and Luhansk oblasts, to target Russian-controlled areas of Kherson and Zaporizhzhia oblasts. (Here)

  3. The United States

     1. The Department of the Treasury (here, press release, fact sheet)

        1. Issued a new determination under Section 1(a)(i) of Executive Order 14024 which added the metals and mining sector of the Russian Federation economy to an ever-growing list of sectors of the Russian economy targeted by this section;

        2. Imposed blocking sanctions on 22 individuals and 83 entities including several banks

        3. Concurrently, OFAC issued four general licenses to allow certain transactions including wind-down transactions related to some of the new designations. Also, OFAC published a number of new FAQs.

     2. The Department of State (press release, fact sheet)

        1. Designated dozens of individuals and entities as sanctions targets (note that some of the designations under E.O. 14024 should be done by the State Department);

        2. Announced visa restrictions on more than a thousand individuals.

     3. The Department of Commerce (here and here)

        1. Added 86 entities to its Entity List;

        2. Introduced new restrictions targeted at Iran to address the use of Iranian UAVs by Russia in its ongoing war against Ukraine;

        3. Increased the export control restrictions against Russia and Belarus expanding the scope of the Russian and Belarusian industry sector restrictions (oil and gas production; commercial and industrial items; chemical and biological precursors) and the ‘luxury goods’ sanctions; and

        4. Issued a Temporary Denial Order suspending the export privileges of a Russian company, as well as a Russian individual, for the unauthorized export of controlled counterintelligence items to Russia and North Korea. (In a relevant action DoJ unsealed a five-count indictment against the individual in question.)

     4. The Office of the United States Trade Representative (here)

        1. Increased tariffs related to several Russian goods.

  4. The European Council (here, here, and here)

     1. imposed several asset-freezing sanctions;

     2. Expanded its export controls;

     3. Introduce more detailed reporting obligations on funds and economic resources belonging to listed individuals and entities; and

     4. Introduced new restrictions on broadcasting, the energy sector, and the ability of Russian nationals to hold positions related to critical infrastructure in Europe.

  5. Canada (here and here)

     1. Imposed several blocking sanctions; and

     2. Expanded its export controls.

The Recommendations of the Week

• I highly recommend watching the conversation between Deputy Secretary, U.S. Department of the Treasury, Wally Adeyemo, and Global Comanaging Partner and Chief Strategy Officer, K2 Integrity, Juan Zarate, about the state of sanctions against Russia. (Here)

• Read through the United States Attorney General's Statement on the Anniversary of Russia’s Invasion of Ukraine. (Here)