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Last week's major developments in sanctions - November 14th to November 18th, 2022

Monday, November 14

  • This week started with a coordinated action against human rights violations in Iran in the wake of the killing of Mahsa Amini, a 22-year-old woman, while she was in "Morality Police" custody. In particular:

    1. The UK imposed blocking sanctions on 24 individuals who have been involved in and ordered the crackdown on protests. (OFSI Notice, Press Release)

    2. The EU Council imposed blocking sanctions on 29 individuals and three entities for their role in the death of Mahsa Amini and the violent response to the recent demonstrations in Iran. (Council Decision 2234, Council Decision 2235, Press Release)

Notably not all of the recently sanctioned persons by the EU or UK or both have been sanctioned by the U.S. government.

  • The United States imposed blocking sanctions on14 individuals and 28 entities under its Russia sanctions program for helping Russia procure military supplies and for being considered as elites or enablers of the Russian government. (Here, the Department of the Treasury's press release, the Department of State's press release)

  • The EU Council imposed blocking sanctions on two top-level commanders of the IRGC and two subsections of the IRGC for their role in providing Unmanned Aerial Vehicles to Russia which have been used in Russia's war against Ukraine. These designations were not made pursuant to the Iran sanctions but under the Russia sanctions regime of the EU. (Here)

  • The EU Council also imposed blocking sanctions on ten individuals and one entity under the EU's sanctions regime against the proliferation and the use of chemical weapons. (Here, Press Release)

  • In a very busy day for the EU Council, the Council made a few changes to bring its DRC sanctions regime in line with that of the UN by amending the criteria for the designation of persons and entities to be subject to the restrictive measures set out in paragraphs 9 and 11 of UNSCR 1807 (2008), as well as the scope of the obligation to notify the Sanctions Committee established pursuant to UNSCR 1533 (2004) of shipments of arms and related materiel for the DRC, or any provision of technical assistance, financing, brokering services and other services related to military activities in the DRC. (Here)

Tuesday, November 15

  • OFAC imposed blocking sanctions on two individuals and three entities involved in the production or ongoing transfer to Russia of Iranian unmanned aerial vehicles. As part of this action, OFAC amended the designation of three entities (IRGC Air Force, PMC Wagner, and Qods Aviation Industries) by designating them under Russia program in addition to the existing sanctions programs pursuant to which they were already sanctioned. (Here, the Department of the Treasury's press release, the Department of State's press release)

  • OFAC issued General License 21 which is very limited and allows transactions that are ordinarily incident and necessary to limited safety and environmental activities of certain sanctioned persons and vessels. OFAC also published FAQ 1097 to explain the new general license.

  • The U.S. Department of State imposed a travel ban (a type of sanctions) on former Belizean Minister John Birchman Saldivar for his involvement in significant corruption and his immediate family members. (Here)

Wednesday, November 16

Thursday, November 17

  • OFSI issued a general license allowing payments to utility companies for gas and electricity by UK designated persons who own or rent properties in the UK. (Here)

  • OFAC designated two individuals under its Counter Narcotics program for trafficking “rainbow fentanyl” and other deadly drugs to the United States. (Here, the Department of the Treasury's press release)

  • OFAC also imposed blocking sanctions on13 companies in multiple jurisdictions facilitating the sale of Iranian petrochemicals and petroleum products to buyers in East Asia under the Iran sanctions program of OFAC. (Here, the Department of the Treasury's press release, the Department of State's press release)

  • The U.S. Department of Commerce's Bureau of Industry and Security updated its Pakistan Due Diligence guidance. (Here)

Friday, November 18

  • OFAC imposed blocking sanctions on two individuals and three entities under the U.S. Global Magnitsky program for their role in exploiting the Guatemalan mining sector and corruption. (Here, the Department of the Treasury's press release, the Department of State's press release)

  • OFAC issued General License 54 under the Russian Harmful Foreign Activities Sanctions Regulations authoring all transactions ordinarily incident and necessary to the purchase or receipt of any debt or equity securities of VEON Ltd that were issued prior to June 6, 2022. VEON Ltd is a telecom company whose debt and equity securities were impacted by the investment-related bans against Russia. (Here)

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