Last week's major developments in sanctions - November 20th to November 24th, 2023

Monday, November 20

• The U.S. Department of State imposed travel bans (a type of sanction) against designated two members of the Armed Forces in Russia for their involvement in gross violations of human rights in Ukraine, making them and their family members ineligible for entry into the United States. (The Department of State’s press statement)

Tuesday, November 21

• The U.S. government brought a large multi-agency action against Binance for alleged violations of various U.S. laws including the Bank Secrecy Act, the International Emergency Economic Power Act, and the Commodity Exchange Act. As a result of these actions, Binance and its CEO pleaded guilty and agreed to (i) pay an aggregated financial penalty of USD 4,316,126,163 (ii) go through monitorship for many years, and (iii) improve Binance’s compliance program. Here are the links relevant to this action:

  1. Department of Justice’s press release;

  2. CFTC's press release;

  3. Department of the Treasury’s press release;

     1. OFAC’s press release;

     2. FinCEN’s press release;

     3. IRS Criminal Investigation’s press release.

• The Bureau of Industry and Security added four entities to BIS’s Entity List for their role in the circumvention of the U.S. sanctions against Russia and Venezuela. (Federal Register Notice, and BIS press release)

• UK's Export Control Joint Unit published an updated version of its "UK strategic export controls" guidance. (Here)

Wednesday, November 22

• There was no major update on this day.

Thursday, November 23

• France imposed asset-freezing sanctions against two individuals pursuant to its autonomous counter-terrorism sanctions. (Here)

Friday, November 24

• The U.S. Department of State imposed travel bans (a type of sanction) against designated a former Colombian General for his involvement in gross violation of human rights. As a result of this action, he and his family are ineligible for entry into the United States. (The Department of State's press statement)

• OFSI extended the validity of General License – INT/2023/3566356 (Correspondent Banking Payments related to certain designated banks under the UK's Belarus sanctions regime) until December 14, 2023. (Here)

Recommendation of the Week

• This week's recommendation is a very interesting sanctions-related case that is ongoing in the UK: Nassani & Ors, R (On the Application Of) v Secretary of State for Foreign, Commonwealth And Development Affairs. In short, the claimants challenged the legality of the UK's sanctions program against Syria. The judge dismissed most of the challenges but let two of them - one about remittances and one about correspondence - move forward.