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Last week's major developments in sanctions - March 27th to March 31st, 2023

Monday, March 27

  • The UK's Office of Financial Sanctions Implementation (OFSI) added three individuals to its list of asset-freeze sanctions targets under the country's Myanmar sanctions regime. (Here, press release)

  • The UK also imposed asset-freezing sanctions against seven individuals in Iran under the UK's Iran sanctions regime. (Here, press release)

  • The EU Council imposed asset-freezing sanctions on eight individuals and one entity responsible for serious human rights violations in Iran. (Here, press release)

Tuesday, March 28

  • OFAC imposed asset-freeze sanctions on six individuals and two entities who were allegedly part of a drug trafficking network that support the Syrian regime. (Here, the Department of the Treasury's press release, the Department of State's press release)

  • OFSI also imposed asset-freeze sanctions on 11 individuals for their role in the drug trade and for supporting the Syrian regime under the UK's sanctions regime against Syria. (Here, press release)

  • OFSI extended general licenses INT/2022/1834876 (Charities and Interim Managers and trustees under its Russia sanctions regime) and INT/2022/1678476 (Amsterdam Trade Bank N.V. - Winding Down, basic needs and insolvency under its Russia sanctions regime)

Wednesday, March 29

  • France added one individual to its list of sanctions targets under the country's autonomous counter-terrorism sanctions program. (Here) At the same time, four individuals were delisted as their designation period expired without being extended.

Thursday, March 30

  • The Bureau of Industry and Security (BIS) of the U.S. Department of Commerce issued an order denying the export privileges of two companies, and their owner, for a period of 20 years. The allegations were violations of EAR by exporting goods to Jordan with the knowledge that they would be re-exported to Iran, failure to maintain appropriate records, and making false or misleading statements to Federal Bureau of Investigation and BIS Special Agents. (Here)

  • On a busy day for BIS, it took the following actions:

    1. Published a dedicated page related to "Promoting Human Rights and Democracy," where it gathers various export controls to counter the use of items subject to the Export Administration Regulations (EAR) that could enable human rights abuses or repression of democracy throughout the world (here);

    2. Published e Export Controls and Human Rights Initiative Code of Conduct (here, the Department of State's press release); and

    3. Added eleven entities based in Burma, the People’s Republic of China, Nicaragua, and Russia to the Entity List for enabling or engaging in human rights abuses around the world. (Here)

  • OFAC imposed asset-freeze sanctions on one individual who attempted to facilitate arms deals between Russia and the Democratic People’s Republic of Korea under its DPRK sanctions program. (Here, the Department of the Treasury's press release, the Department of State's press release)

  • The International Court of Justice delivered its judgment in the case concerning Certain Iranian Assets (Islamic Republic of Iran v. United States of America). Both sides scored a number of wins. (Press release, the Judgement, the Department of State's press release, Iran's Ministry of Foreign Affairs press release)

  • OFAC published a very interesting FAQ about the "exit-tax" in Russia and stated that U.S. persons would require a specific license to pay it to the Russian Central Bank. (Here)

  • OFAC announced a $30 million settlement agreement with Wells Fargo. (Here) Federal Reserve Board also fined Wells Fargo $67.8 million for inadequate oversight of sanctions risk at its subsidiary bank. (Here) In my opinion, the facts of this case are extraordinary. OFAC fined Wells Fargo not because it processed transactions in apparent violation of sanctions but because it provided software to a bank in Europe that used the software to trade with countries under the U.S. sanctions. This is alarming for all U.S. companies that provide software globally!

Friday, March 31

  • The EU Council finally modified some of its sanctions regimes to implement the UN Security Council resolution 2664 (2022) which introduced Humanitarian Exemptions in the UN sanctions and called for such exemptions to be included in member states' sanctions programs. (Here, press release)The U.S. and UK already modified their respective sanctions program to allow certain humanitarian activities in line with the UNSC resolution 2664.

  • The EU Council extended its Iran Human Rights sanctions regime for another year through April 13, 2024. (Here)

  • The EU Council decided that the prohibition on broadcasting RT Arabic Sputnik Arabic should be effective starting from April 10, 2023. (Here)

  • OFAC announced a settlement with Uphold HQ Inc. for $72,230.32 to settle its potential civil liability for apparent violations of sanctions against Iran, Cuba, and Venezuela. (Here) Two takeaways:

    1. If you have the information about where a user is residing, PLEASE use that for sanctions compliance purposes; and

    2. The employees of blocked governments like Venezuela in this case, are also blocked (without the need for further listing).

  • OFAC imposed asset-freeze sanctions on Tabacalera del Este S.A., Paraguay's largest cigarette manufacturer, under its Global Magnitsky sanctions program. (Here) Concurrently, OFAC issued a general license allowing certain transactions related to a tobacco Master Settlement Agreement, entered into on November 23, 1998, between certain U.S. state and territory attorneys general and certain tobacco companies. (Here) OFAC also issued an FAQ to explain the newly issued general license. (Here)

  • The United States Department of State published the 2023 Hong Kong Policy Act Report. (Here)

The Recommendation of the Week

  • Check out this report about Swiss prosecutors' action against four bank executives who allegedly oversaw accounts that helped move millions of dollars of what is believed to be Russian president Vladimir Putin’s wealth.

  • The Central Bank of the UAE announced that it decided to cancel MTS Bank’s Abu Dhabi license. MTS was granted a license by the CBUAE in early February, then was designated by OFAC on February 24, 2023.


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