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Last week's major developments in sanctions - Jun. 28th to Jul. 2nd, 2021

Monday, June 28th

- The U.S. Department of State designated a leader of ISIS in Greater Sahara as a Specially Designated Global Terrorist (SDGT). (Here)

Tuesday, June 29th - No major development on this day.

Wednesday, June 30th

- OFSI published a blog post about reasonableness test in licensing. (Here)

- In a non-sanctions-related development, FinCEN, the agency in charge of AML/CTF regulations in the U.S., published its priorities in AML/CTF. Those priorities are: corruption, cybercrime, domestic and international terrorist financing, fraud, transnational criminal organizations, drug trafficking organizations, human trafficking and human smuggling, and proliferation financing. (Here)

- In another FinCEN-related development, the agency signaled that it will move to establish a "no-action letter" process. (Here) OFAC already has no-action letters as one of its responses to apparent violations. (See 31 C.F.R. Appendix A to part 501)

- Finally on this FinCEN-loaded day, the agency provided an update on AML Act implementation. (Here)

- A relevant committee of the UN Security Council removed one Iraqi entity from its list of sanctions targets. (Here)

Thursday, July 1st

- The U.S. Department of State released a long list of corrupt and undemocratic actors for Guatemala, Honduras, and El Salvador. (Here) There is no sanctions implication attached to this action yet those whose name appears on this list could be future targets for financial sanctions or travel bans (if not already targeted).

Friday, July 2nd

- OFAC added 22 individuals to the SDN list under its Burma program. (Here) Concurrently, BIS added four entities in Burma to the Entity List of the agency. (Here)

- OFAC removed the names of three individuals from the SDN list. Those three names had been added under its Iran program. (Here)

- In an administrative move, OFAC announced that it will remove ICC Sanctions regulation from the Code of Federal Regulation. (Here)

Recommendations of the week

- First, take a look at the updated AML/CTF guidelines of UAE Central bank. (Here)

- Then, take a look at Australia's FIU, AUSTRAC, post about source of funds. (Here)

- If you would like to know more about China's Anti-Sanctions law, you can take a look at Steptoe's recent post about it. (Here)

- Finally, read (or listen to) this WSJ article about the difficulties faced by some major clothing brands due to the concerns over the use of forced labor in the Xinjiang region of China.


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