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Last week's major developments in sanctions - Jan. 18 to Jan. 22, 2021

Updated: Jan 29, 2021

Monday, January 18th:

- This week started with the extension of asset freezing orders initially issued on Jan. 18, 2018, (here) for 10 individuals and 11 entities pursuant to Frane autonomous sanctions for another 6 months. (Here) The targets are all related to confront Syria WMD efforts. Several of the targets were also sanctioned by OFAC (here).

- In an export control-related development, the EU Council adopted a decision establishing a set of common features that end-user certificates for the export of Small Arms and Light Weapons and their ammunition will have to respect. (Here)

- The Security Council Committee established pursuant to resolution 1518 (2003) approved the removal of two Iraqi individuals from its sanctions lists. (Here) As of January 23rd, neither EU nor OFAC removed these two individuals from their lists. However, OFSI took their names off it lists on Jan. 19th indicating how efficient it is. (Here)

Tuesday, January 19th: - OFSI in a series of actions made several amendments to its sanctions list and deleted a number of entries on its list. (Here)

- The United States Department of State imposed visa restrictions on Tanzanian officials responsible for or complicit in undermining Tanzania’s October 28, 2020, general elections.(Here)

- The United States Department of State in accordance with section 219 of the Immigration and Nationality Act designated Ansarallah as a Foreign Terrorist Organization. At the same time, the Department of State designated the group and a number of its leaders under SDGT program of the United Sates. Concurrently, OFAC issued a number of General Licenses ("GL") to authorize humanitarian activities. OFAC also published three FAQs explaining the new sanctions against Ansarallah. Among them, FAQ 876 is interesting because it states "activity that would be authorized by GLs 9, 10, 11, and 12 if engaged in by a U.S. person would not be considered “significant” for the purposes of a secondary sanctions determination under E.O. 13224, as amended." This language, even though is specific to the GLs and E.O. mentioned here, may indicate that OFAC in general will not go after a non-U.S. person for an activity that is authorized for a U.S. person. Yet, this reminds everyone that OFAC GLs are not applicable to non-U.S. persons. The reason is that the United States may not impose prohibitions over whom it has no jurisdiction. So, the act of those non-U.S. persons would not be prohibited in the first place. (Here)

- OFAC added 3 individuals, 14 entities, and 6 vessels pursuant to its Venezuela program. These targets were allegedly part of a network related to the Venezuelan oil sector. (Here) It is notable that the targets were located in many different countries which, in turn, confirmed the United States' determination (at least that of the previous administration) in going after those helping the government of Venezuela selling its oil. (See the relevant the Dept. of State press release.)

- OFAC designated an entity and a vessel pursuant to Section 232 of CAATSA for knowingly selling, leasing, or providing to the Russian Federation goods, services, technology, information, or support for the construction of Russian energy export pipelines. (Here)

- In an AML-related development, FinCEN published answers to frequently asked questions regarding suspicious activity reporting and other AML Considerations. (Here)

- Iran sanctioned 11 high-ranking officials of the Trump administration. The asset freezing measures and travel bans are imposed against Donald Trump, Mike Pompeo, Mark Esper, Christopher Miller, Steven Mnuchin, Gina Haspel, Jared Kushner, John Bolton, Brian Hook, Elliott Abrams, and Andrea Gacki. (Here in Farsi)

Wednesday, January 20th:

- France Ministry of the Economy and Finance imposed sanctions against 7 individuals pursuant to its autonomous sanctions. (Here)

Thursday, January 21st:

- France Ministry of the Economy and Finance imposed sanctions against additional 8 individuals pursuant to its autonomous sanctions. (Here)

- OFSI took 11 names off its sanctions list related to North Korea and it made amendments to several other entries across different sanctions regimes. (Here)

- President Biden issued a National Security Directive relevant to actions to be taken to address the global COVID-19 crisis. The directive, among other things, required the Secretary of State, the Secretary of the Treasury, and the Secretary of Commerce, in consultation with the Secretary of HHS and the Administrator of USAID, to promptly review existing United States and multilateral financial and economic sanctions to evaluate whether they are unduly hindering responses to the COVID-19 pandemic, and to provide recommendations to the President, through the Assistant to the President for National Security Affairs and the COVID-19 Response Coordinator, for any changes in approach.

Friday, January 22nd:

- There was no major development on this day.

Recommendation of the week:

- This week I would like to recommend an article written by Kate Cronin-Furman published in Foreign Policy about the recent Determination of the Secretary of State on Atrocities in Xinjiang. (Here)


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