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Last week's major developments in sanctions - June 19th to June 23rd, 2023

Monday, June 19

  • OFSI added two individuals under its Syria sanctions regime and two individuals under its Democratic Republic of Congo to the list of sanctions targets subject to asset-freezing restrictions. (Syria designations, DRC designations)

  • Canada modified some of its sanctions regulations to implement the UN sanctions, to incorporate Resolution 2664 (2022) on December 9, 2022, which asked the member states to include carve-outs for certain humanitarian activities. (Here)

  • The EU Council adopted two minor sanctions-related decisions:

    1. Council Decision (CFSP) 2023/1188 extended the sanctions imposed pursuant to Council Decision 2014/386/CFSP concerning restrictive measures in response to the illegal annexation of Crimea and Sevastopol till 23 June 2024; and

    2. Council Decision (CFSP) 2023/1189 removed two individuals from the list of targets under the EU Democratic Republic of Congo's sanctions program.

Tuesday, June 20

  • OFSI amended General Licence INT-2022-1947936 (Humanitarian Activity) to the definition of non-government controlled Ukrainian territory to capture Kherson and Zaporizhzhia oblasts and to update the Annex I of Designated Financial Institutions to capture financial institutions designated since 7 July 2022.

  • The United States Department of State imposed visa restrictions (a type of sanction) on the mayor of the municipality of Struga, North Macedonia, his wife, and his three children, as generally ineligible for entry into the United States, due to his involvement in significant corruption pursuant to Section 7031(c) of the Department of State, Foreign Operations, and Related Programs Appropriations Act, 2023. (Here)

  • OFAC imposed asset-freezing sanctions on two South Sudanese individuals involved in conflict-related sexual violence. in South Sudan. Concurrently, the Department of State designated two ISIS leaders as Specially Designated Global Terrorists, under Executive Order 13224 for their involvement in sexual violence against Yezidis and the abduction and enslavement of Yezidi women and girls. (Here, the Department of the Treasury's press release, and the Department of State's press release)

  • OFAC announced a settlement agreement with Swedbank Latvia in the amount of $3,430,900. Swedbank Latvia caused a U.S. bank to violate its sanctions obligations by routing transactions initiated by one of its clients in Crimea through Swedbank Latvia's online banking platform. This is another reminder that financial institutions (traditional or not) must implement controls on IP addresses associated with comprehensively sanctioned jurisdictions. (Here)

Wednesday, June 21

  • OFSI updated its Russia Guidance to reflect the provisions in the Russia (Sanctions) (EU Exit) (Amendment) (No.2) Regulations 2023.

  • OFAC imposed asset-freezing sanctions on Burma’s Ministry of Defense and two state-controlled banks in Burma under the United States sanctions program against Burma. Concurrently, OFAC issued a General License that authorizes the wind-down of transactions involving the two recently-designated banks. (Here, the Department of the Treasury's press release, and the Department of State's press release)

  • The United States Department of State announced a new visa restriction policy under Section 212(a)(3)(C) of the Immigration and Nationality Act that targets foreign government officials and agents (and their immediate family members) who have intervened in a manner beyond the reasonable provision of consular services to assist fugitives accused or convicted of serious crimes to evade the U.S. justice system. (Here)

Thursday, June 22

  • There was no major development on this day.

Friday, June 23

  • The EU Council (finally) adopted its 11th sanctions package against Russia. The 11th package consists of two Decisions:

    1. Council Decision (CFSP) 2023/1218 (relevant press release)

      1. Amended some of the designations grounds;

      2. Created a new designation ground extended in order to cover legal persons, entities, or bodies operating in the Russian IT sector that hold a license administered by the Federal Security Service of the Russian Federation Center for Licensing, Certification, and Protection of State Secrets or a weapons and military equipment license administered by the Russian Ministry of Industry and Trade;

      3. Added several entities and individuals to the list of asset-freezing sanctions targets (despite some earlier speculations, none of them were located in third countries known to be involved in sanctions evasion); and

      4. Amended and granted certain derogations

    2. Council Decision (CFSP) 2023/1217 (relevant press release)

      1. Prohibited the transit via the territory of Russia of goods and technology which might contribute to Russia’s military and technological enhancement or to the development of its defense and security sector, goods and technology suited for use in aviation or space industry, and jet fuel and fuel additives, exported from the Union;

      2. Introduce a "threat" against third countries (outside of the EU) who do not collaborate in preventing circumvention of sanctions and export control restrictions to Russia;

      3. Added 87 new entities to the list of legal persons, entities set out in Annex IV to Decision 2014/512/CFSP. Those are not subject to asset-freezing measures; only tighter export restrictions regarding dual-use goods and technology, as well as goods and technology which might contribute to the technological enhancement of Russia’s defense and security sector will be applicable to them;

      4. Expended the list of items that contribute to Russia’s military and technological enhancement

      5. Prohibited the sale, license, or transfer in any other way of intellectual property rights or trade secrets related to the goods and technology whose sale, supply, transfer, or export to a person, entity, or body in Russia or for use in Russia is prohibited;

      6. Expanded some transportation-related reactions including a prohibition on docking at EU ports for vessels that engage in ship-to-ship transfers in breach of the prohibition of the importation of seaborne crude to EU or price cap mechanism.

  • OFAC imposed asset-freezing sanctions on two Russian Federal Security Service officers under its Russia sanctions program. (Here, the Department of the Treasury's press release, and the Department of State's press release)

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