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Last week's major developments in sanctions - Nov. 15th to Nov. 19th, 2021

Monday, November 15th

- This week started the addition of four individuals to the EU list of financial sanctions targets. The new names were added under the Syrian sanctions regime. (Council's Decision, press release)

- The EU Council also expanded the scope of sanctions against Belarus by adding a new ground for addition to the sanctions lists under the Belarus sanctions regime. The new ground grants the authority to designate "natural or legal persons, entities or bodies organizing or contributing to activities by the Lukashenka regime that facilitate: (i) the illegal crossing of the external borders of the Union; or (ii) the transfer of prohibited goods and the illegal transfer of restricted goods, including hazardous goods, into the territory of a Member State." (Council's Decision, press release) Please note that as of the day of this publication, there has been no designation pursuant to this recently added ground. In addition to the expansion of the scope of sanctions, the Council carved out certain provisions of insurance/re-insurance that were previously restricted. (Council's Decision)

- The UK's OFSI added eight individuals to its list of financial sanctions targets. (Here) Some of these new additions were already listed by OFAC.

- OFAC also took action against nine Nicaraguan officials as well as the Public Ministry of Nicaragua following the country's Nov. 7th elections. (Here, Dept. Treasury's press release, Dept. of State's press release)

Tuesday, November 16th - There was no major development on this day.

Wednesday, November 17th

- There was no major development on this day.

Thursday, November 18th

- The President of the U.S. issued a new Executive Order and terminated the national emergency which was declared in Executive Order 13712. As such, OFAC removed the names on the SDN list with the [BURUNDI] tag. (Dept. Treasury's press release, Dept. of State's press release)

- OFAC designated a senior Houthi military official pursuant to the Yemen program. (Here. Dept. of Treasury's press release, Dept. of State's press release)

- Iran sanctions were already complex because of the different authorities used to impose sanctions. Now, OFAC made it even more complex by adding six individuals and one entity in Iran pursuant to Executive Order 13848 (Imposing Certain Sanctions in the Event of Foreign Interference in a United States Election). (Here, Dept. Treasury's press release, Dept. of State's press release) Concurrently, the DoJ published a press release announcing charges against two of the designated individuals. (Dept. of Justice's press release)

Friday, November 19th

-There was no major development on this day.

Recommendations of the week

- If you want to read more about the new sanctions against Belarus, read this client alert prepared by Hughes Hubbard & Reed.

- This one is not about sanctions yet it is important in my opinion. FinCEN published a Notice about Environmental Crimes. The notice has an appendix which describes different types of Environmental Crimes. (Here)


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