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Last week's major developments in sanctions - February 27th to March 3rd, 2023

Monday, February 27

  • The Journal of the EU published last week's Council Decision concerning the EU terrorist list. Under the EU counter-terrorism sanctions regime the Council shall review the terrorist list at regular intervals and at least once every six months to ensure that there are grounds for keeping them on the list. As expected, the EU did not make any changes in its latest review. (Council Decision, press release)

  • The Journal of the EU also published the Council's decision to extend the Union's sanctions against Belarus for another year. (Here, press release)

  • OFAC issued Supplemental Guidance for the Provision of Humanitarian Assistance to its 2014 Guidance Related to the Provision of Humanitarian Assistance by Not-for-Profit Non-Governmental Organizations. (Here) Related to this, check out this webinar on charitable assistance to persons affected by the recent earthquakes in southern Turkiye and northern Syria.

  • OFSI published reporting forms related to the Russian oil and petroleum products price caps. (Here)

  • BIS imposed an administrative penalty of $2,777,750 on 3D Systems Corp (3D) to settle 19 violations by 3D of the Export Administration Regulations by exporting controlled aerospace technology and metal alloy powder to China without the required license, and by exporting controlled technology to Germany without the required license. (Here) In addition to BIS, the Department of State announced an administrative settlement with 3D to resolve alleged violations of the Arms Export Control Act and the International Traffic in Arms Regulations. (Here)

Tuesday, February 28

  • The EU Commission published four FAQs concerning the EU prohibition on the provision of specialized financial messaging services to certain Russian banks. (Here)

  • OFAC imposed blocking sanctions on an arms trafficker who has conspired to purchase firearms in the United States, smuggle the firearms to Mexico, and supply the firearms to CJNG, a sanctioned cartel in Mexico. (Here, the Department of the Treasury press release)

Wednesday, March 1

  • OFAC imposed blocking sanctions on three entities and two individuals under its North Korea sanctions program. (Here, the Department of the Treasury press release, the Department of State press release)

  • OFAC announced a USD 332,500 settlement agreement with Godfrey Phillips India Limited (GFI), a tobacco company in India, for apparent violations of U.S. sanctions against North Korea. GFI exported tobacco to North Korea via an intermediary in Thailand and received payments for the shipment in USD either at its bank account at a non-U.S. bank in India or the India-based branch of a U.S. bank. In addition to causing U.S.-based financial institutions to breach U.S. sanctions by processing USD transactions destined for a non-U.S. bank, GFI caused the branch of a U.S. financial institution to violate U.S. sanctions. (Here) Note that even if the India-based branch of a U.S. bank was a subsidiary (as opposed to a branch), an apparent violation would have been very likely as a result of the expansion of U.S. jurisdiction under the North Korea sanctions program in 2022 which brought persons that are owned or controlled by a U.S. financial institution and established or maintained outside the United States under U.S. jurisdiction. (For more information, see 31 C.F.R. § 510.214)

Thursday, March 2

  • The U.S. Department of State imposed blocking sanctions on six entities for their role in the transport or sale of Iranian petroleum products or petrochemical products. The Department of State also identified 20 vessels owned by the newly listed entities. Concurrently, OFAC issued General License O to authorize certain transactions related to wind-down and limited safety and environmental activities involving the newly listed vessels. OFAC also published two new FAQs (1119 and 1120) related to this development. (Here, the Department of State press release) You may wonder why these designations were made by the Department of State and not by OFAC. The reason is the language of the relevant sections of Executive Order 13846 which authorizes the Secretary of State to designate.

  • OFAC imposed blocking sanctions on eight entities for being involved in a timeshare fraud scheme related to properties located in Mexico. The sanctioned entities are all related to a Mexican cartel that has been designated under the U.S. counter-narcotics sanctions program. Concurrently, OFAC published an alert to inform the public that some of the scammers have falsely claimed to be representatives of OFAC and asked for victims' information or asked them to pay fees or taxes. (Here, the Alert, the Department of the Treasury's press release)

  • BIS, the U.S. Department of Justice (DOJ), and OFAC issued a joint Compliance Note to alert the public regarding sanctions evasion efforts related to Russia sanctions. The alert has identified several red flags that can help the public identify sanctions evasion efforts. (Here, press release)

  • BIS added 37 entities to the Entity List for contributing to Russia’s military, supporting the People’s Republic of China (PRC) military modernization, and facilitating or engaging in human rights abuses in Burma and PRC. (Here)

  • DOJ announced that two U.S. citizens were arrested for an alleged years-long scheme to circumvent U.S. export laws that included the illegal export of aviation-related technology to Russia. (Here)

  • In an administrative action, the EU Council decided to extend Decision 2014/119, which is the basis of part of the EU's sanctions regime against Russia, through March 6, 2024. (Here)

Friday, March 3

  • The Attorney General of the United States made a trip to Ukraine. As part of his remarks, he mentioned the ongoing work of the Department to seize illicit Russian assets for the benefit of the people of Ukraine and to prosecute those who facilitate the evasion of sanctions imposed on Russia, through Task Force KleptoCapture. (Here) On the same day, U.S. Deputy Attorney General, who was attending the American Bar Association's 38th Annual National Institute on White Collar Crime, announced that the Justice Department will add more than 25 new prosecutors who will investigate and prosecute sanctions evasion, export control violations, and similar economic crimes. (Here) These two statements are in line with G7 increased efforts to enforce sanctions against Russia.

  • OFAC imposed blocking sanctions under its Global Magnitsky program on three individuals in Russia for their involvement in serious human rights abuse against human rights defender, Vladimir Kara-Murza. Concurrently, the Department of State also imposed blocking sanctions on three individuals under E.O. 14024 for being or having been leaders, officials, senior executive officers, or members of the board of directors of the Government of the Russian Federation. The Department of State also imposed several visa restrictions against two of the individuals sanctioned by OFAC on this day. (Here, the Department of the Treasury press release, the Department of State press release)

The Recommendation of the Week


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