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Last week's major developments in sanctions - January 23rd to January 27th, 2023

Monday, January 23

  • This week started with the imposition of blocking sanctions on several individuals and entities involved in human rights abuses in Iran by the U.S., UK, and EU. More specifically:

    1. The United States designated several high-level IRGC members. Additionally, the IRGC Cooperative Foundation, an economic conglomerate established by senior IRGC officials to manage the group’s investments and presence in numerous sectors of the Iranian economy, which was already subject to blocking sanctions under the United States non-proliferation and counter-terrorism programs, was designated under E.O. 13553 (related to the situation Human Rights in Iran). (Here, the Department of the Treasury press release, the Department of State press release)

    2. The UK designated six individuals including high-ranked commanders of IRGC and two entities including the IRGC Cooperative Foundation. (Here, press release)

    3. The EU Council added 18 individuals and 19 entities to its list of sanctions targets subject to blocking sanctions. (Here, press release)

  • A former Special Agent in Charge of the FBI New York Counterintelligence Division and another individual were charged with violation of the U.S. sanctions. The defendants allegedly provided services to Oleg Deripaska, an SDN under the U.S. Russia sanctions program. (The Department of Justice press release, indictment)

  • The EU Council adopted two the following sanctions-related decision:

    1. 2023/160 amending the Union's sanctions regime against Somalia to reflect the changes made by the UNSC; and

    2. 2023/159 extending the validity of the EU sanctions regime against Tunisia through Jan 31, 2024, and amended some of the entries of the sanctioned persons under this regime.

Tuesday, January 24

Wednesday, January 25

  • The Department of State imposed two visa bans (a type of sanction) against the former President of Panama (here) and specific individuals in Nigeria (their names were not published) (here) using the authority granted in Section 7031(c) of the Department of State, Foreign Operations, and Related Programs Appropriate Act and Section 212(a)(3)C) of the Immigration and Nationality Act, respectively.

  • FinCEN issued an alert to financial institutions on potential investments in the U.S. commercial real estate sector by sanctioned Russian elites, oligarchs, their family members, and front entities. (Here)

Thursday, January 26

  • The United States (both the Treasury and State Department) designated 17 individuals, 11 entities, five aircraft, and 2 vessels related to Wagner Group or otherwise supporting Russia's war against Ukraine under various authorities. As part of this action, OFAC designated the Wagner Group as a transnational criminal organization pursuant to E.O. 13581, as amended. The Department of State also imposed visa bans on hundreds of individuals related to Russia. (Here, the Department of the Treasury press release, the Department of State press release, and the Department of State fact sheet)

  • OFAC designated the former President of Paraguay and the current Vice President for their involvement in the rampant corruption in Paraguay as well as four entities owned or controlled by the former President. Notably, two of the designated entities are located in the United States. OFAC, concurrently, issued two general licenses (GL 5 and GL 6 under the global Magnistly program) to authorize certain activities related to winding down or divestment from designated entities. (Here, the Department of the Treasury press release, the Department of State press release)

Friday, January 27

  • The relevant UNSC sanctions committed added ISIS South East Asia to its list of sanctions targets. (Here)

  • The EU Council extended the validity of its Russia sanctions regime for another six months through July 31, 2023. (Here)

  • The Department of State imposed visa bans against two former Serbian National Assembly Representatives for their involvement in significant corruption under Section 7031(c) of the annual Department of State, Foreign Operations, and Related Programs Appropriations Act. (Here)

  • BIS renewed the temporary denial of export privileges against Venezuelan airline Emtrasur. (Here)

The Recommendation of the Week

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