top of page

Last week's major developments in sanctions - Jan. 31st to Feb. 4th, 2022

Monday, January 31st

- On the first anniversary of the coup in Burma OFAC designated seven individuals and two entities to the SDN list under its Burma program. (Here, Department of Treasury's press release, Department of State press release) The UK's Office of Foreign Sanctions Implementation ("OFSI") also added three individuals to its list of sanctions targets under the country's Myanmar sanctions regime. (Here)

- OFAC delisted a vessel which was allegedly involved in a ship to ship transfer of Iranian oil in June 2021. (Here)

- In an arms-export related development, the Department of State announced a settlement with Torrey Pines Logic, Inc. of San Diego, California and Dr. Leonid B. Volfson in the amount of $840,000. (Here)

Tuesday, February 1st

- No major development on this day.

Wednesday, February 2nd

- OFSI removed one individual from its list of sanctions targets. The removed person used to be designated under the Iran (Human Rights) regime of the UK. (Here)

- OFAC published seven new FAQs in the context of Afghanistan confirming the inclusion of many different activities under existing general licenses for humanitarian purposes in Afghanistan. (Here)

Thursday, February 3rd

- The EU Council had a busy day:

  • It reviewed the so-called EU Terrorists List and removed one entry from it. (Council Decision, press release)

  • Amended Council Decision 2011/486/CFSP (Establishing Afghanistan/Taliban Sanctions) by adding an important carve out allowing the processing and payment of funds, other financial assets or economic resources, and the provision of goods and services necessary to ensure the timely delivery of humanitarian assistance and other activities that support basic human needs in Afghanistan or to support such activities. (Council Decision)

  • Amended the grounds for keeping certain funds frozen even after a designated person is deceased in the context of Tunisia sanctions regime. (Council Decision)

  • Added five persons to the list of targets under the Mali sanctions regime. (Council Decision, press release)

- OFAC designated an Indonesian NGO for its alleged support of terrorisms in Syria. (Here, Department of Treasury's press release, Department of State press release)

- The U.S. Department of State imposed visa bans (a type of sanctions) on a number of Belarusian nationals for their involvement in serious, extraterritorial counter-dissident activity. The bans were imposed pursuant to the so-called Khashoggi Ban, a global visa restriction policy pursuant to Section 212(a)(3)(C) of the Immigration and Nationality Act. (Here)

- In an export control-related development, The U.S. Department of Commerce Bureau of Industry and Security published the final rule which clarified, reorganized, and made minor corrections to the provisions of the foreign-direct product (FDP) rules. (Here)

Friday, February 4th

- No major development on this day.

Recommendations of the week

- The Department of States' press conference on Monday, Jan. 31st, included some interesting conversations about sanctions, their deterrence, and why it is important not to disclose them in advance. In case you are interested, watch from 27:02 of the press conference. (Here)

- Want to know more about the EU Blocking statute and how the recent decision of the Court of Justice of the European Union in Bank Melli Iran v. Telekom Deutschland may affect it in the future? Check the analysis of Hughes Hubbard Paris' team published by NYU Program on Corporate Compliance and Enforcement. (Here)

- Did you miss OFSI's webinars for the Charity Sector? You can still see the slides presented by OFSI here. (Thanks OFSI! This is really helpful. I hope OFAC follows suit.)


bottom of page