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Last week's major developments in sanctions - Jan. 25 to Jan. 29, 2021

Monday, January 25th:

- This week let's start with a couple of EU actions. The Official Journal of the European Union published two sanctions-related decisions, and three sets of regulations.

- In line with the EU actions, France also delisted the two Iraqi and four Tunisian targets from French list of blocked assets (Le registre des gels des avoirs).

- OFAC issued GL No. 13 authorizing through 12:01 a.m. ET, February 26, 2021, all (with some exceptions mentioned in section (b) of the GL) transactions and activities involving Ansarallah, or any entity in which Ansarallah owns, directly or indirectly, a 50 percent or greater interest, which became prohibited following Ansarallah designation as FTO and SDGT by the previous administration.

An interesting point about this license was that it was singed by Bradley T Smith, the Acting Director of OFAC. I haven's seen any news confirming Andrea Gacki's departure. I think we will know more soon.

OFAC also published FAQ 876 in which it explained (re-explained) that non-U.S. person will not be exposed to the risk of sanctions by engaging in an activity that is authorized for a U.S. person if transacting with Ansarallah.

Tuesday, January 26th: - There was no major development on this day.

Wednesday, January 27th:

- The saga of restrictions against Communist Chinese Military Companies continues with the issuance of GL No. 1A which replaced GL No. 1, issued on Jan. 8, 2021. The new GL, authorizes through 9:30 a.m. ET, May 27, 2021, all transactions and activities prohibited by section 1(a) of Executive Order (E.O.) 13959, as amended , involving publicly traded securities of an entity whose name closely matches, but does not exactly match, the name of a Communist Chinese military company as appears on the Non-SDN CCMC list of OFAC. Please note that this GL is only about those "close matches" and has nothing to do with those entities listed on the Non-SDN CCMC list (regardless of the fact that an entity is a subsidiary or not). OFAC also published two FAQs explaining the scope of the GL. (FAQ 878 and FAQ 879)

Thursday, January 28th:

- There was no major development on this day.

Friday, January 29th:

- The Department of Justice unsealed an indictment charging a national of the People’s Republic of China with participating in a criminal conspiracy from 2012-2015 to violate U.S. export laws by shipping U.S. power amplifiers to China. DOJ also published a non-prosecution agreement with Avnet Asia Pte. Ltd. a Singapore company and global distributor of electronic components for unauthorized exports of controlled items to PRC and Iran. As part of the agreement, Avnet agreed to pay $1,161,000 in lie of civil and/or criminal forfeiture, $347,000 monetary penalty, and additional $1,721,000 for settlement with Department of Commerce due to violations of EAR. (Total of $3,229,000) (Here)

Recommendations of the week:

- This week I would like to recommend a thorough presentation on the UK sanctions. The panelists discuss in detail the architecture of the UK sanctions which came into effect Jan. 1st, 2021 CET. (Here)

- I would also like to recommend a quick read about a specific license issued for the benefit an SDN under Global Magnistky program. (NYT article - FT article)


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