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Last week's major developments in sanctions - Jan. 24th to Jan. 28th, 2022

Monday, January 24th

- This week started with the removal of one individual from the UN's ISIL (Da’esh) and Al‑Qaida Sanctions List. (Here)

- OFAC issued two General Licenses under its Ukraine-related program: GL 13Q, and GL 15K

GL 13Q allows transaction related to divestment from GAZ Group shares and GL 15K allows certain activities that are necessary for manufacturing and selling GAZ Group vehicles.

Both of these General Licenses allowed certain transactions that were otherwise prohibited only for 90 days. The previous versions of these licenses were issued with a year-long authorization. The shortening of the validity of General Licenses is another way for OFAC to impose pressure. Concurrently, OFAC amended several FAQs to reflect the new licenses. As a reminder, GAZ Group was sanctioned for being owned by Oleg Deripaska in April 2018.

Tuesday, January 25th

- No major development on this day.

Wednesday, January 26th

- OFAC along with some other departments issued an advisory note on heightened risks associated with doing business in Burma. (Here, Department of Treasury's press release, Department of State press release) The advisory came few days after two of the major oil companies announced their departure from Burma. (Here)

Thursday, January 27th

- In keeping up with its increasing trend in export control-related prosecutions, the U.S. DoJ published another indictment related to illegal export to Iran. (Here)

Friday, January 28th

- The Afghanistan (Sanctions) (EU Exit) (Amendment) Regulations 2022 came into force. It was an important change because it provided major carve outs for humanitarian assistance and other activities that support basic human needs in Afghanistan. According to the new regulations, OFSI amended its Charity Guidance. (Here)

- OFSI amended its Monetary penalties for breaches of financial sanctions. (Here)

- OFSI is joining OFAC in making changes on Friday! OFSI removed four individuals from its sanctions lists under its Iran (Human Rights) regime and amended several entries under its Venezuela regime. (Here for Iran, and here for Venezuela)

Recommendations of the week

- If you are in the UK you may want to take a look at this: the UK Financial Conduct Authority reminded the authorized and registered firms in the UK of the importance of having competent and capable heads of compliance and MLROs. (Here)

- Like last week, everyone is talking about Russia and potential new sanctions if the situation at its border with Ukraine escalates. A lot of the commentaries are of a political nature yet I found this client alert prepared by the Steptoe's team very helpful.


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