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Last week's major developments in sanctions - Jan. 17th to Jan. 21st, 2022

Monday, January 17th

- This week started with the delisting of two entries from the French list of sanction targets as their six-month period of designations expired without being extended. (The last designation decree)

- UK provided some updates about the upcoming changes to its sanctions lists. (Here) If you want to know more please check out this post by Paige Berges, counsel at Ropes & Gray LLP.

- The Security Council ISIL (Da’esh) and Al-Qaida Sanctions Committee removes three entries from its Sanctions List. (Here)

Tuesday, January 18th

- OFSI provided an updated link to its annual review pursuant to Section 30 of the Sanctions and Anti Money Laundering Act 2018. (Here)

- OFAC designated three individuals and one entity due to their role as financial facilitators for Hizballah. (Here, Department of the Treasury's press release, Department of State's press release)

- The U.S. charged another Iranian-American dual national for alleged violations of IEEPA caused by export of goods and technology to Iran. (Here)

Wednesday, January 19th

- OFSI replaced the entry for the former ambassador of Libya to Chad, Quren Salih Quren AL QADHAFI. (Here)

Thursday, January 20th

- OFAC designated four individuals using the authority granted in E.O. 14024. The four individuals, two of whom are members of the Ukraine's Parliament, were allegedly involved activities designed to destabilize Ukraine. (Here, Department of the Treasury's press release, Department of State's press release)

- OFAC issued General License GI in the Venezuela Program which continues to delay U.S. persons’ ability to enforce bondholder rights to the CITGO shares serving as collateral for the Petróleos de Venezuela, S.A. (PdVSA) 2020 8.5% bond until on or afterJanuary 20, 2023. Concurrently, OFAC updated FAQ 595 to reflect the new General License. (Here)

- OFAC published two notices of amendments for public inspection. First one was about Transnational Criminal Organizations Sanctions Regulations. OFAC reissued the regulations in their entirety to provide more clarity. Second, OFAC changed the definition of the phrase,"applicable schedule amount," so that it will automatically rise with OFAC’s civil monetary penalties which in turn removes the necessity of updating the applicable schedule amount every year. (Here)

Friday, January 21st

- OFSI designated one individual under its Counter Terrorism regime. (Here)

- OFAC designated a network of Hizballah financial facilitators which included three individuals and ten companies. All of the designation were made under the Global Counter Terrorism program of the U.S. Treasury. (Here, Department of the Treasury's press release, Department of State's press release)

Recommendations of the week

- The fourth issue of Financial Institutions Sanctions Compliance (FISC) is out. For more information on how to get a copy please check out their website.

- A LOT is going on with respect to Russia and potential sweeping sanctions against it. I found this article published by Dow Jones useful. It explains the potential sanctions that could be imposed against Russia without commenting on the politics of what is going on on the ground.


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