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Last week's major developments in sanctions - Mar. 1st to Mar. 5th, 2021

Monday, March 1st:

- This week started with no major development. Yet, take a look at the Department of State press briefing where the word 'sanction' was repeated 21 times! (Link)

Tuesday, March 2nd: - EU used its Global Human Rights regime for the first time by designating four individuals which deemed to be responsible for serious human rights violations, including arbitrary arrests and detentions, as well as widespread and systematic repression of freedom of peaceful assembly and of association, and freedom of opinion and expression in Russia. (Council Regulations) (Press release) The four listed individuals are:

  1. Alexander Bastrykin - Head of the Investigative Committee of the Russian Federation,

  2. Igor Krasnov - the Prosecutor General,

  3. Viktor Zolotov - Head of the National Guard, and

  4. Alexander Kalashnikov - Head of the Federal Prison Service

- OFAC added two high-ranking Houthis officials to the SDN list pursuant to its Yemen program (E.O. 13611). (Treasury press release) (Department of State press release)

- OFAC, BIS, and the Department of State reacted to Russia’s poisoning and subsequent imprisonment of Russian opposition figure Aleksey Navalny.

  • OFAC

    • Added six Russian governments officials pursuant to section 1(a)(ii)(A) of E.O. 13661, and one pursuant to 1(a)(ii)(A) of E.O. 13661 and section 1(a)(iv) of E.O. 13382. (Here)

    • Issued General License 1B replacing General License 1A to cover the recent designations authorities used against Federal Security Service. (Here)

    • Amended FAQs 501, 502, and 503 to reflect the new license 1B.

  • The Department of State

    • Designated six entities and one individual pursuant to Section 1(a)(ii) of E.O. 13382.

    • Added six entities to CAATSA 231 List which increase the risk of being sanctioned for those who knowingly engage in a transaction with the listed entities. (Here)

    • Imposed sanction pursuant to the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991. The Secretary of the State made a determination that the Government of the Russian Federation has used a chemical weapon against its own nationals, in violation of the Chemical Weapons Convention and therefore imposed 5 types of sanctions. (Here)

  • BIS

Wednesday, March 3rd:

- 15 individuals were delisted in France. In fact, their six-month long designation period pursuant to article Article L562-2 of France monetary and finance code was expired.

- OFAC designated an individual pursuant to the Foreign Narcotics Kingpin Designation Act (Kingpin Act). (Here) (Andrea Gacki's name was mentioned in the press release as the director of OFAC ending some speculations stemmed from the signatures of Bradley Smith as the acting director of OFAC.)

- BIS added four entities in Burma (Ministry of Defence, Ministry of Home Affairs, Myanmar Economic Corporation, and Myanmar Economic Holdings Limited) to the Entity List. (Here) BIS also moved Burma from Country Group B and to Country Group D:1. (More restrictions on licensing as a results). Finally, BIS made Burma subject to ‘military end use’ and ‘military end user’ restrictions under the EAR. (Here) (Press release)

Thursday, March 4th:

- EU extended one of its sanctions regimes against Russia for another year. It made some changes to the list of those targeted by the regime in question. (Council's Decision) (Press release)

Friday, March 5th:

- The Security Council Committee established pursuant to resolution 1591 (2005) concerning Sudan approved the removal of one individual from its list of targets. (Here)

- The Department of State imposed travel bans against Ihor Kolomoyskyy, a former Ukrainian public official, his wife and his two children pursuant to section 7031(c) of the Department of State, Foreign Operations, and Related Programs Appropriations Act, 2020. (Here)

Recommendations of the week:

- This week I would like to recommend to you a very interesting podcast in which Erich Ferrari, among other things, spoke about the importance of delistings in sanctions programs and how the role of sanctions has shifted in the U.S. domestic politics. (Here)


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