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Last week's major developments in sanctions - Mar. 8th to Mar. 12th, 2021

Monday, March 8th:

- This week started with the revocation of the controversial Specific License granted to Dan Geltler. (Department of State press release)

Tuesday, March 9th: - In an Anti-Money Laundering related development, FinCEN published a notice on the risk associated with the trade in antiquities and art. As a reminder, OFAC had issued an advisory note last year regarding potential sanctions risks arising from dealings in high-value artwork.

- Travel bans pursuant to section 7031(c) of the Department of State, Foreign Operations, and Related Programs Appropriations Act, 2020 is becoming a thing! The U.S. Department of State imposed sanctions (travel bans) on two IRGC interrogators for their involvement in gross violations of human rights. (Here)

Wednesday, March 10th

- OFSI published an updated version of its guidance on "monetary penalties for breaches of financial sanctions" which will be applied from April 1, 2021. (Here)

- OFAC designated two adult children of the commander-in-chief of the Burmese military forces, Min Aung Hlaing, who was initially designated as an SDN on December 10, 2019, under Global Magnitsky program (here) and later under the new Burma program on Feb. 11, 2021 (here). In addition, OFAC added six entities owned by the two children to its SDN list. (Treasury press release) (Department of State press release)

- Department of State took action against ISIS affiliates in Africa by designating two organizations as Foreign Terrorist Organization (FTO) and Specially Designated Global Terrorist (SDGT). Department of State also designated the leaders of these two organizations as SDGT. (Here) Some of the targets were already on the SDN list pursuant to the Democratic Republic of Congo, and Global Magnitsky programs. (Here)

Thursday, March 11th:

- There was no major development on this day.

Friday, March 12th:

- Following the expiration of the designation period under article L562-2 of the Monetary and Financial code of France, Teddy SADSAOUD came off the France national list of asset freezing. (The initial designation)

- The EU Council extended the sanction regime which was imposed following the Crimea crisis for six months. (Here) (Press release)

- The EU Council repealed Decision 2011/172/CFSP which imposed sanctions against Egypt. (Here) It means that the sanctions regime against Egypt does not exist anymore. (Press release)

- In an interesting development concerning sanctions against companies listed as "Communist Chinese Military Company," a D.C. court granted Xiaomi a preliminary injunction on Friday. (Here) The court order stopped (for now) the restrictions against Xiaomi pursuant to E.O 13959 that would have come into effect on March 15th. As a result OFAC published an FAQ over the weekend, clarifying that restrictions against Xiaomi are not applicable. OFAC also published another FAQ which is related to the listing of Luokong Technology Corporation, clarifying that the restrictions will be effective from May 8th, 2021. (Here)

Recommendations of the week:

- This week I would like to recommend to you my article about how to improve relationships with banks published by Association of Certified Sanctions Specialists. Feel free to let me know what you think about it. (Here)


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