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Last week's major developments in sanctions - November 13th to November 17th, 2023

Monday, November 13

  • The EU Council extended the validity of its blocking sanctions under its Venezuela sanctions regime for another six months. (Decision, and press release) Notably, the designation period was extended to only six months instead of one year, which would be the normal extension period. The Council shortened the designation period in light of recent positive developments in Venezuelan politics that led to a political agreement of 17 October 2023, in Barbados.

  • OFSI amended General Licence INT/2022/1552576 by removing the Annex which had listed the arbitration-related costs and changing the definition of Arbitration Costs to mirror what the London Court of International Arbitration has indicated on its website. (Here)

Tuesday, November 14

  • France imposed asset-freezing sanctions on two individuals related to Hamas under its autonomous counter-terrorism sanctions. (Here)

  • OFAC imposed asset-freezing sanctions on eight individuals and two entities under its counter-terrorism program for their engagements with Hamas. OFAC also changed the designation of one entity from OFAC’s non-SDN Palestinian Legislative Council List to the Specially Designated Nationals List. (Here, the Department of the Treasury’s press release, and the Department of State’s press release)

  • OFAC issued an “OFAC Compliance Communiqué: Guidance for the Provision of Humanitarian Assistance to the Palestinian People” in response to questions from the NGO community and the general public on how to provide humanitarian assistance while complying with OFAC sanctions. (Here)

  • In concert with OFAC, OFSI imposed asset-freezing sanctions on six Hamas-related individuals. Most of those designated by OFSI were already sanctioned by OFAC. (Press release)

  • OFSI issued General Licence - INT/2023/3749168: Israel and the Occupied Palestinian Territories humanitarian activity. (Here)

Wednesday, November 15

  • OFAC imposed asset-freezing sanctions on a major drug trafficker in Costa Rica under the U.S. counter-narcotic sanctions program. (Here, and press release)

Thursday, November 16

  • On a busy day on the U.S. sanctions front:

    1. OFAC imposed asset-freezing sanctions on eight individuals and six entities under its Western Balkans-related and Russia sanctions programs. Concurrently, the U.S. Department of State, which is the designating authority for certain grounds of designations under Executive Order 14024, imposed asset-freezing sanctions on two individuals and twelve entities, who were involved in corruption and support of Russia in the Western Balkans. (Here, the Department of the Treasury’s press release, and the Department of State’s press release)

    2. OFAC issued two General Licenses to authorize wind-down activities (General License 2) and certain medical or agricultural-related activities (General License 3) concerning Orka Holding AD, which was sanctioned on this day. Note that Orka Holding AD, a holding company in Macedonia, has medical and agricultural arms. OFAC also published an FAQ to clarify the scope of General License 3. (Here)

    3. OFAC imposed blocking sanctions on three entities (and identified three vessels as blocked property) due to their roles in carrying Russian crude oil above the Coalition-agreed price cap while using services from providers located in jurisdictions that are part of the Price Cap Coalition. (Here, the Department of the Treasury’s press release, and the Department of State’s press release) Concurrently, OFAC issued General License 77 to authorize certain activities related to the safety and environmental concerns that involve some of the parties that were designated on this day. (Here)

    4. OFAC issued General Licenses 8M and 45A under its Venezuela sanctions program, replacing the older versions of those licenses. (Here)

Friday, November 17

  • Federal Register published the BIS' notice regarding the removal of "The Ministry of Public Security’s Institute of Forensic Science of China" from the Entity List. (Here) This was one of the outcomes of the Biden-Xi meeting on Wednesday. (For more background information: here)

  • The Department of Justice announced the conviction of two Texans on charges of attempting to violate IEEPA, conspiracy to violate IEEPA, and conspiracy to commit money laundering in connection with their attempt to transact in sanctioned Iranian petroleum and launder the proceeds. (Here)

  • In the latest episode of what constitutes control under the UK sanctions laws saga, the UK government published a new guidance detailing what control means to them. (Here)

  • OFAC imposed asset-freezing sanctions on six individuals under its counter-terrorism sanctions regime while the U.S. Department of State imposed asset-freezing sanctions on one entity under the same program. All newly designated parties were related to Iran's activities in Iraq. (Here, the Department of the Treasury’s press release, and the Department of State’s press release)

  • OFAC published four additional FAQs in the context of Venezuela sanctions. (Here)

Recommendation of the Week

  • The Royal United Service Institute ("RUSI") had an informative conversation with the EU Sanctions Envoy, David O’Sullivan, about sanctions evasions, data, and the role of the private sector. Check it out here.


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