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Last week's major developments in sanctions - July 31st to August 4th, 2023

Monday, July 31

  • OFSI imposed asset-freezing sanctions on six individuals involved in the trial of Vladimir Kara-Murza, a dual British national persecuted by the Russian regime for his anti-war stance, under the UK's sanctions regime against Russia. (Here, and press release)

  • OFAC imposed asset-freezing sanctions on 20 individuals and 29 entities related to ISIS under its Global Counter-Terrorism sanctions program. (Here, and the Department of the Treasury's press release)

  • OFAC also imposed asset-freezing sanctions on four individuals for undermining the Dayton Peace Agreement pursuant to its Balkan-related sanctions program. (Here, and the Department of the Treasury's press release)

Tuesday, August 1

  • OFSI issued General Licence INT/2023/3263556 for insolvency payments related to GTLK Companies (Russia's largest leasing company) and their subsidiaries. Unlike many other OFSI General Licenses, this one has a notification requirement. (Here)

Wednesday, August 2

  • The EU Commission published three additional FAQs about its Russia sanctions regime. (Here)

Thursday, August 3

  • The EU Council expanded the scope of its sanctions against Belarus and also designated more individuals and entities under its Belarus sanctions regime. The new sanctions include restrictions on the exportation of goods and technology suited for use in aviation and the space industry, prohibition of the sale, supply, transfer, or export of firearms, and expanded restrictions on the exportation of dual-use goods and technology to Belarus. (Decision for additional asset-freezing sanctions, Decision for expanded export restrictions, and the press release)

Friday, August 4

  • The EU Council amended its sanctions regime against Guinea-Bissau sanctions by inserting some humanitarian authorizations. (Here)

  • OFAC amended the Mali Sanctions Regulations and reissued them in their entirety. (Here)

  • OFSI updated some of its oil price cap-related compliance forms and instructions for using them. (Here)

  • The United States Department of State issued a press statement noting that OFAC will not renew General Licenses issued for the wind-down activities related to recently designated Burmese banks, Myanma Foreign Trade Bank, and Myanma Investment and Commercial Bank. The statement in the relevant part read that "following the expiration of GL 5 on August 5 at 12:01 a.m. (EST), the United States will continue to carefully monitor compliance and scrutinize transactions with an MFTB or MICB nexus to counter evasion or other behavior that contravenes the intent of these designations and U.S. policy. We will pursue enforcement actions as appropriate." (Here) I have not seen such statements that"insist" on the expiration of a general license.

Recommendation of the Week

  • Listen to a recent episode of the Jordan Harbinger Show where Juan Zarate, the Global Co-Managing Partner at K2 Integrity, discussed how the United States wields its financial power against terrorism, rogue states, and global crime syndicates. (Here)

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