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Last week's major developments in sanctions - May 23rd to May 27th, 2022

For a detailed post about Russia-related sanctions developments you can check: Special Edition - New Sanctions Against Russia 🇷🇺

To see non-Russia- related previous weeks' updates you can check: Weekly Updates

Monday, May 23rd

  • OFSI issued a General License allowing transactions related to purchase of tickets from e PJSC Aeroflot, JSC Rossiya Airlines, JSC Ural Airlines, Russian Railways or their subsidiaries. (Here)

  • The U.S. Department of Treasury, State, Commerce, and Labor issued an advisory related to doing business in Sudan. The advisory reminds the U.S. business of risks of doing business in Sudan while encouraging responsible investments. As far as sanctions are concerned, the advisory touches upon different list-based sanctions programs in which a target may be located in Sudan. (Here)

Tuesday, May 24th

  • OFAC designated four individuals and six entities to its SDN list under the Global Counter Terrorisms program of the U.S. The new designated persons were providing financial assistance to Hamas, an SDN and an FTO. (Here, Treasury's press release, Department of State's press release)

  • In a new type of announcement, OFAC announced that it will not renew General License 9C under the Russian Harmful Foreign Activities Sanctions regulations. (Here)

Wednesday, May 25th

  • OFAC added ten individuals and nine entities to its SDN list due to their role in selling oil for Iran's Revolutionary Guard. (Here, Treasury's press release, Department of State's press release)

  • On Feb. 28, 2022, OFAC issued Directive 4 under Executive Order 14024 prohibiting transactions involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation. To mitigate the negative impact of that prohibition on the U.S. person, OFAC issued General License 13A and authorized payments of taxes, fees, or import duties, and purchase or receive permits, licenses, registrations, or certifications to those entities through September 30, 2022. (Here)

Thursday, May 26th

  • China and Russia vetoed a resolution that would expand the UN sanctions against the Democratic People's Republic of Korea. (Here)

Friday, May 27th

  • OFAC issued General License 8J in the context of the Venezuelan sanctions which replaced General License 8I. Both licenses authorize limited activities for five major U.S. companies. (Here)

  • OFAC designated one individual and three entities under its non-proliferation sanctions program. These recently added persons allegedly supported North Korea's efforts to develop weapons of mass destruction. (Here, Treasury's press release, Department of State's press release)

  • OFAC announced a settlement with Banco Popular de Puerto Rico in the amount of $255,937.86. The reason for the settlement was that the bank processed transactions for employees of the government of Venezuela. This was an interesting enforcement action as it showed that it does not matter if the employees are not high-ranked. If an entity is sanctioned then (almost) anyone acting on its behalf should be treated the same as the sanctioned person. (Here)

  • In a busy day for the UNSC, it granted travel exemptions to three targets under its Libya sanctions, amended six entries under its ISIL & Al-Qaida sanctions. (Here for Libya, here and here for ISIL sanctions)

Recommendations of the week

  • Robert Malley, the special envoy for nuclear talks with Iran, appeared before the Senate Foreign Relations Committee to talk about the ongoing indirect talks with Iran to revive JCPOA. See the recording here and the text of his testimony here.

  • Read about another bump in Iran-U.S. relationship that relates to sanctions against Iran (and potentially Russia): the U.S. seized a ship carrying Iranian oil on a Russian-operated ship near Greece. (Here) As a response, Iran seized two Greek tankers in the Persian Gulf. (Here) There was no official statement on this story as of the time this issue was published.


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