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Last week's major developments in sanctions - Jan. 10th to Jan. 14th, 2022

Monday, January 10th

- The European Council imposed sanctions on seven individuals and three entities in light of what the Council called as “the worsening situation in Nicaragua.” (Council’s Decision, press release) The U.S. also designated six individuals under its Nicaragua program. (Here, the Department of the Treasury’s press release, the Department of State’s press release) The designation packages of the EU and the U.S. did not have any overlapping yet some of those designated by the EU were previously designated by the U.S.

- The European Council (after a considerable delay!) added one entity that was designated by the UNSC on December 21, 2021 to the list of targets pursuant to its Central African Republic sanctions regime. (Council’s Decision) Such long delays in designations by the EU Councils shows the importance of the recently amended ​Article L562-3-1​ of the French Monetary and Finance Code which makes the UN sanctions designation automatically applicable in France.

- OFSI published a new version of its sanctions lists. There was no substantive change to the list as part of these actions, rather it was how the OFSI maintains its lists. It’s important to check your screening systems’ setup to ensure the new format is being screened properly. (Here) OFSI will be holding a webinar about the recent changes in format. (Registration link)

- The U.S. Department of State condemned China’s move last month which imposed sanctions against a number of U.S. citizens. (Here)

Tuesday, January 11th

- OFAC announced a settlement agreement with Sojitz (Hong Kong), a Hong Kong-based company, in the amount of $5,228,298. The reason for the settlement was a number of apparent violations which Sojitz caused by processing transactions through the U.S. financial system, where those transactions were related to some high density polyethylene resin that was from an Iranina origin. In its notice OFAC stated that Sojitz has a decent compliance set-up however, a number of employees hid the origin of the polyethylene from the compliance team of Sojits. (Here)

Wednesday, January 12th

- OFSI made some cleanups in its financial sanctions list by amending one entry related to South Sudan and 62 ISIS-related entries following the changes made by the UNSC in December last year. (ISIS amendment notice, South Sudan amendment notice)

- In response to the recent missile launches by the DPRK, OFAC designated seven individuals and one entity to the SDN list. (Here, Department of the Treasury's press release, Department of State's press release)

Thursday, January 13th

- The EU Council prolonged the decision which put in place the European sectoral sanctions against Russia for another six months. (Decision, press release)

- OFSI made changes to the information related to two targets by designating them under its Global Human Rights regime. (Here, and here)

- France extended the designation period for 19 entries that were designated pursuant to article L. 562-3 of the French Monetary and Finance Code. (Here) Additionally, eight names were removed from the French autonomous list of sanctions as their designation period ended.

Friday, January 14th

- No major development on this day.

Recommendation of the week

- The UK’s Foreign, Commonwealth & Development Office published the UK's Annual Sanctions Report for 2021. If you are interested to see how UK did in 2021 when it came to sanctions, you can find the report here: Annual Sanctions Report for 2021


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