Monday, November 7
OFAC imposed blocking sanctions on four individuals and eight entities for supporting ISIS in South Africa. The designations were made under the United States global counter-terrorism sanctions program. (Here, the Department of the Treasury's press release, the Department of State's press release)
Tuesday, November 8
The EU Council added 19 individuals, including the Minister of Investment and Foreign Economic Relations and the Chief Justice of the Supreme Court, and one entity, State Administration Council, to the list of sanctioned persons under the EU Myanmar's sanctions program. (Here, press release)
In three separate administrative actions, the EU Council:
Extended the validity of the sanctions regime against Turkey for unauthorized drilling activities in the Eastern Mediterranean for another year through 12 November 2023 (here, press release);
Amended the list of sanctioned persons under its Mali sanctions regime to reflect the changes that were made earlier by the UNCS (here); and
Amended the list of sanctioned persons under its North Korea sanctions regime to reflect the changes that were made earlier by the UNCS (here).
OFAC designated two individuals under the United States sanctions program against North Korea because they have acted on behalf of Air Koryo, an entity previously designated by OFAC for operating in the transportation industry in the DPRK economy. (Here, the Department of the Treasury's press release, the Department of State's press release)
Interestingly, OFAC delisted Tornado Cash and simultaneously designated it under the United States cyber sanctions and North Korea sanctions programs. OFAC also published a new FAQ and updated three FAQs. The new FAQ tries to show that OFAC has broad authority to designate various types of organizations and entities including Decentralized Autonomous Organizations. (This view is in line with this post published on Sanctions Expert right after the initial designations in August.) The FAQ further clarifies that OFAC has not designated Tornado Cash’s individual founders, developers, members of the DAO, or users, or other persons involved in supporting Tornado Cash at this time. (Here, the Department of the Treasury's press release, the Department of State's press release)
OFAC also imposed blocking sanctions on one individual and one entity that facilitated weapons purchases for Burma’s military regime under the United States Burma sanctions program. (Here, the Department of the Treasury's press release, the Department of State's press release)
Wednesday, November 9
OFSI updated its Russia sanctions guidance to clarify the application of the prohibition on providing financial services and funds relating to restricted goods and G7 dependency and further goods. (Here)
OFAC imposed blocking sanctions on three individuals and nine entities for supplying illicit fentanyl, synthetic stimulants, cannabinoids, and opioids to U.S. markets through internet sales and a host of shell companies. (Here, the Department of the Treasury's press release)
OFAC also imposed blocking sanctions on two individuals for supporting others who were previously sanctioned under the United States global counter-terrorism sanctions program. (Here, the Department of the Treasury's press release, the Department of State's press release)
Thursday, November 10
OFSI published its 2021-2 annual review. (Here) Notably the report states that from 22 February to 20 October 2022, a total of £18.39 billion in frozen funds were reported to OFSI as being held by or on behalf of persons designated under the Russia sanctions regime.
OFAC issued General License 53 under its Russia sanctions program authorizing U.S. persons to engage in all transactions ordinarily incident and necessary to the official business of diplomatic or consular missions of the Government of the Russian Federation, Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation. OFAC published an FAQ to clarify the new general license. (Here)
OFAC issued General License 8D under its Russia sanctions program which replaced General License 8C which was set to expire on December 5, 2022. The new general license is valid through May 15, 2023.
Friday, November 11
OFSI amended several entries on its sanctions list across various regimes including North Korea, Global Human Rights, Russia, and Myanmar.
Recommendation of the week
This week's recommendation is a long read about the validity and enforceability of sanctions clauses. Yet it is very interesting to see how the court ruled in favor of JP Morgan Chase which had relied on a sanctions clause in a letter of credit and avoided the confirmation due to the involvement of a sanctioned vessel. (The Judgement)