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Last week's major developments in sanctions - July 10th to July 14th, 2023

Monday, July 10

  • The UK's Export Control Joint Unit (ECJU) published a Notice to Exporters concerning the Export Control (Amendment) Regulations 2023 which came into effect on July 13, 2023. The new regulations tightened the export control restrictions related to Haiti by requiring a license for all military goods destined for Haiti that transit the UK would require a license. The new regulations also updated the list of dual-use items in line with recent updates by the Wassenaar Arrangement and the Australia Group. (Here)

  • OFAC replaced General License 40A with 40B under its Venezuela sanctions program, which now expires on July 10, 2023. The General License in question authorizes all transactions related to the exportation or reexportation of liquefied petroleum gas to Venezuela, involving the Government of Venezuela, Petróleos de Venezuela SA. (Here)

  • OFAC published part 526 under title 31 of the Code of Federal Regulations. The new regulations are published pursuant to Executive Order 14078 (Bolstering Efforts to Bring Hostages and Wrongfully Detained United States Nationals Home). (Here)

Tuesday, July 11

  • OFAC imposed asset-freezing sanctions on the Director of Serbia’s Security Information Agency for his involvement in corruption under Executive Order 14033 (Blocking Property and Suspending Entry Into the United States of Certain Persons Contributing to the Destabilizing Situation in the Western Balkans). (Here, the Department of the Treasury's press release)

Wednesday, July 12

  • OFSI imposed asset-freezing sanctions on six entities under its Sudan sanctions regime for providing funding and arms to the militias. (Here, press release)

  • The French Treasury extended the asset-freezing sanctions on three individuals and three entities under Article L562-3 of the French Monetary Code, which authorizes the imposition of sanctions on those who commit, attempt to commit, finance, or facilitate any prohibited or sanctioned activity by the UNSC or by the EU. (Here)

  • OFSI updated its general guidance for financial sanctions under the Sanctions and Anti-Money Laundering Act 2018 to reflect some of the changes in its licensing policy.

  • OFAC imposed asset-freezing sanctions on ten individuals and one entity under the United States Counter-Narcotics sanctions program. (Here, the Department of the Treasury's press release)

Thursday, July 13

  • The United States Secretary of the Treasury, Janet L. Yellen, announced the now former OFAC's Director, Andrea Gacki, as the new Director of FinCEN. (Here)

  • The U.S. Department of State imposed visa restrictions (a type of sanction) under Section 7031(c) of the Department of State, Foreign Operations, and Related Programs Appropriations Act, 2023, against the former Panamanian President due to his involvement in significant corruption. (Here)

Friday, July 14

  • The EU Council extended its humanitarian exemption under its Syria sanctions regime until 24 February 2024. (Here, press release) This exemption was initially introduced in the aftermath of the devastating earthquake that hit Türkiye and Syria in February 2023.

Recommendation of the Week

  • The European Court of Justice issued a ruling that was about the Blocking Statute of the EU. In IFIC Holding v Commission, the Court dismissed IFIC's claims and sided with the Commission concerning a license it had granted to Clearstream Banking AG that authorized Clearstream to comply with certain U.S. sanctions against Iran. Find out more here.

  • The UK's Ministry of Justice is offering a webinar on July 18, 2023, at 10 am GMT about the recent ban that prevents UK lawyers from advising Russian companies in certain business deals. The new ban has been criticized by the Law Society of England and Wales due to potentially severe unintended consequences. Read more about their stance here.


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