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Last week's major developments in sanctions - May 10th to May 14th, 2021

Monday, May 10th

- This started with a major export control-related development. The EU Council adopted a regulation modernizing the EU system for the control of exports, brokering, technical assistance, transit and transfer of dual-use items. (Here)

Tuesday, May 11th - The U.S. Treasury added seven individuals to the SDN list. The seven individuals were related to Hizballah and they were added pursuant to the anti-terrorisms program of the United States. (Here, Treasury press release, Department of State press release) Concurrently, OFAC deleted and modified a number of entries to the SDN list.

Wednesday, May 12th

- The Court of Justice of the European Union, the highest court of the European Union in EU-related laws, rendered a long-waited opinion concerning the EU blocking statute. In short, the court said "a decision by an EU [person] to terminate a contractual relationship with an Iranian [person] subject to US primary sanctions should be regarded as invalid if it cannot be justified on any ground other than the desire to comply with US legislation providing for secondary sanctions against non-US [person ...]." (Court's opinion) Interestingly, the Advocate General in this case stated:

"In conclusion, I cannot avoid observing that it gives me no particular pleasure to arrive at this particular result. As the facts of this case have highlighted, the EU blocking statute is a very blunt instrument, designed as it is to sterilise the intrusive extraterritorial effects of US sanctions within the Union. This sterilisation method will inevitably bring casualties in its wake and many may think that Telekom Deutschland will be among the first to suffer, not least given its large US operations. As I have already hinted, these are matters which the EU legislature may well wish to ponder and consider."

- OFAC added seven individuals and two entities while removing two other entities from the SDN list, all related to the Kingpin Act authority. (Here, press release)

- U.S. Department of State imposed travel bans on the former Office Director of the so-called “Central Leading Group on Preventing and Dealing with Heretical Religions” of Chengdu, Sichuan Province. (Here)

Thursday, May 13th

- The UK OFSI added three individuals to its list of sanctions targets and amended one entry. (Here)

Friday, May 14th

- OFAC amended (effective May 17, 2021) the Narcotics Trafficking Sanctions Regulations, 31 C.F.R. part 536, and the Foreign Narcotics Kingpin Sanctions Regulations, 31 C.F.R. part 598. (Here)

Recommendation of the week

- Following the recent changes in the EU controls on dual use items, I would like to recommend a brief note prepared by BenninkAmar about the recent changes and their implications for the businesses. (Here)


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