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Last week's major developments in sanctions - Jan. 11 to Jan. 15, 2021.

Updated: Jan 18, 2021

Monday, January 11th:

- This week started with the delisting of 7 individuals from French autonomous list.

- OFSI issued a new General License (INT/2020/G1) allowing legal aid payments related to fees and disbursements incurred by the solicitors in the provision of legal services to the designated persons under the Counter Terrorism regimes (there are three of them and this license covers all) of the UK. OFSI concurrently revoked 3 General licenses. One of the three was replaced by the recently-issued General License INT/2020/G1 , yet the two other licenses were not replaced and as a results provision of insurance and the payment of legal fees by third parties which used to be generally licensed are allowed anymore. (Link)

- At 9:30 ET, restrictions imposed by E.O. 13959 came into effect against Communist Chinese military companies.

- OFAC added seven individuals and four entities to its SDN list under Foreign Interference in a U.S. Election program (E.O. 13848). These new targets were all related to Andrii Derkach, a member of Ukrainian parliament. (Link)

- The Department of State, re-designated Cuba as a State Sponsor of Terrorism. (Link) There are several restrictions attached to such designation (mainly of export control nature). This last-minute addition fo Cuba to the SST list was in line with the policy of the the current administration to rollback as much as possible the relaxations done by the Obama's administration aimed at improving the diplomatic relations with Cuba. Taking a country out of this list is not an easy task considering that it the the President who has to request the Speaker of the House and different committees in the House and the Senate for such removal subjected to several conditions.

Tuesday, January 12th: - The Department of States designated five individuals under the authority granted by E.O. 13224 (Specially Designated Global Terrorists). (Link)

- The United States Department of Justice announced charges against three individuals (two in Canada and one in Iran) for their alleged conspiracy to export U.S. goods to Iran. Interestingly, one of the defendants, who is located in Iran, published a statement in which he mentioned that he got to know one of the other co-defendants while the former was in jail in Iran for his political opinions. He also stated (or admitted) that the goods exported to Iran were mainly purchased on Amazon or eBay.

Wednesday, January 13th:

- OFAC listed two individuals and several entities pursuant to E.O. 13876 issued on June 24, 2019, targeting the Supreme Leader of Iran and his close circle. The main targets of this action of the Treasury were the Execution of Imam Khomeini’s Order (EIKO), and Astan Quds Razavi (AQR). The other designations were all related to these two major players in Iran's economy. An interesting point regarding the addition of EIKO to the SDN list is that the COVID vaccine in Iran is being made by this organization. The designation can potentially hamper Iran's fight agains COVID outbreak. (Link)

- The United States Customs and Border Protection issued a Withhold Release Order against cotton products and tomato products produced in Xinjiang based on information that reasonably indicates the use of detainee or prison labor and situations of forced labor. It means that starting January 13, 2021, CBP will detain such products. (Link) (Similar actions are taken by Canada and the UK - link)

Thursday, January 14th:

- OFAC announced a settlement agreement with an Indonesian company, PT Bukit Muria Jaya, in the amount of $1,016,000 due to 28 apparent violations of U.S. sanctions against North Korea. (Link) The apparent violations resulted from exportation of cigarette paper to North Korea. In this case, OFAC exercised jurisdiction over this company due to the use of USD in transactions related to North Korea. (Here is another cigarette-related settlement OFAC had reached with a UAE-based company in July 2020.)

- The Department of State added the leaders of two Foreign Terrorist Groups (as defined in section 219 of the Immigration and Nationality Act) to the SDN list as Specially Designated Global Terrorists. (Link)

- OFAC took a number of actions regarding the new sanctions against Communist Chinese military companies:

  • It issued General License 2 authorizing securities exchanges operated by U.S. persons to engage in transactions involving covered securities through the applicable wind-down periods.

  • It issued four FAQs

    • 871: reiterates what GL2 authorizes for securities exchanges operated by U.S. persons

    • 872: reflects the amended section 1(b) which prohibits possession of in-scope securities by a United States person effective at 11:59 p.m. eastern standard time on November 11, 2021.

    • 873: addresses the change in the definition of transaction in section 4(e) of the E.O. 13959 from "the purchase for value of any publicly traded security," to "the purchase for value, or sale, of any publicly traded security."

    • 874: clarifies the scope of the activities allowed in the applicable wind-down periods

  • It published a new E.O. issued by the President amending E.O. 13959. For your convenience, I incorporated the amendments into the E.O. 13959. (Click here)

- The United States Department of State imposed visa restrictions on People’s Republic of China individuals (including executives of state-owned enterprises and officials of the Chinese Communist Party and People’s Liberation Army (PLA) Navy) responsible for, or complicit in, either the large-scale reclamation, construction, or militarization of disputed outposts in the South China Sea, or the PRC’s use of coercion against Southeast Asian claimants to inhibit their access to offshore resources in the South China Sea. Immediate family members of those targeted by this measure may be subject to these visa restrictions as well. (Link)

- The Bureau of Industry and Security in the Department of Commerce added Chinese National Offshore Oil Corporation (CNOOC) to the Entity List and Chinese company Skyrizon to the Military End-User (MEU) List. (Link)

Friday, January 15th:

- Taking a short break from the United State, on Friday EU added the recently appointed Foreign Minister of Syria, Faisal Mekdad to those target by the EU Syria sanctions regime. (Link) He has been in his new post since November of 2020. As of today, neither the United States nor the UK listed this individual (yet).

- Back to the United States where a lot happened on Friday.

  • First, in relation to Iran:

    • Three already-existing entities on the SDN list are now also designated pursuant to E.O. 13949 (Blocking Property of Certain Persons With Respect to the Conventional Arms Activities of Iran). (Link)

    • Three already-existing entities on the SDN list (Mobarakeh Steel Company, Islamic Republic of Iran Shipping Lines, and the IRISL subsidiary Sapid Shipping) are now also designated pursuant to IFCA. (Link)

    • A China-based, a UAE-based, and two Iran-based companies were added to the SDN list pursuant to authority provided in IFCA. (Link)

    • Two individuals, the Chief Executive Officer of IRISL and the Chief Executive Officer of Mobarakeh Steel Company, were added to the SDN list pursuant to authority provided in IFCA. (Link)

    • Pursuant to section 1245(e)(3) of Iran Freedom and Counter-proliferation Act of 2012 (IFCA), Department of State published a list of 15 additional materials determined to be used in connection with Iran’s nuclear, military, or ballistic missile programs. (Link) (Four materials already listed on October 31, 2019, and later another 22 types of materials were added on July 30, 2020).

    • The Department of State, pursuant to section 1245(e)(2) of IFCA, continued its determination that the Islamic Revolutionary Guard Corps controls Iran’s construction sector. (Such determination was initially made on October 31, 2019 - here) This is not not to be mixed up with section 1(a)(i) of E.O. 13902 in which the President granted the Secretary of the Treasury, in consultation with the Secretary of State, the authority to designate a person who operates in the construction sector of Iranian economy. The E.O. 13902 sanctions are asset freezing sanctions only while the IFCA sanctions are menu-based (even though IFCA provides such authority to asset freeze as well as other types of sanctions).

  • Second, with respect to Cuba:

    • OFAC designated the Cuban Ministry of Interior and the Minister of Interior, Lazaro Alberto Álvarez Casas, for serious human rights abuse, under the Global Magnitsky program of the United States. (Link)

  • Finally, with respect to China and Hong Kong:

    • Following the mass arrests of democracy activists earlier this month in Hong Kong (see here), OFAC designated six PRC and Hong Kong officials pursuant to the E.O. 13936. (Link)

    • OFAC announced the publication of Hong Kong-Related Sanctions Regulations (31 CFR Part 585). (Link)

Recommendation of the week:

- This week I would like to recommend a truly informative resource and that is This website provides great amount of information about various sanctions around the world and in particular in the UK. Also, make sure you subscribe to their unbeatable free email alerts to get all the sanction-related news in your inbox.


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