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Last week's major developments in sanctions - October 30th to November 3rd, 2023

Monday, October 30

  • There was no major sanctions-related development on this day.

Tuesday, October 31

  • OFSI imposed asset-freezing sanctions on five individuals and one entity under its Myanmar (Burma) sanctions regime for being involved in arms deals, supplying restricted goods to the security forces, and financing the military. (Here, press release)

  • OFAC issued a new directive under its Bruma-related sanctions program and prohibited U.S. persons from the provision, exportation, or reexportation, directly or indirectly, of financial services to or for the benefit of Myanma Oil and Gas Enterprise (MOGE) or its property or interests in property. To explain the new prohibition, OFAC published two FAQs. Concurrently, OFAC imposed asset-freezing sanctions on five individuals and three entities. (Here, the Directive, the Department of the Treasury's press release, and the Department of State's press release)

  • The U.S. Department of State imposed travel restrictions (a type of sanctions) against over a dozen individuals, including Public Ministry officials and other public and private sector actors, and their immediate family members, for undermining democracy and the rule of law in Guatemala under Section 212(a)(3)(C) of the Immigration and Nationality Act. (Here, press release)

Wednesday, November 1

  • Brooklyn and Russia sanctions evasion! The Eastern District of New York brought two separate actions against two sets of defendants who unlawfully conspired to export controlled, dual-use technologies to Russia. (DoJ press release)

  • A Dutch court has sentenced a Russian citizen to 18 months in prison and imposed a monetary fine equal to 200,000 euros against his company for breaching EU sanctions against Russia. (Here)

Thursday, November 2

  • OFAC imposed asset-freezing sanctions against 37 individuals and 192 entities under its Russia sanctions program. Some of the designated persons were involved in sanctions evasion while others were involved in targeted sectors of the Russian economy including the energy and financial sectors. One of the targeted entities under this day's actions was Sistema Public Joint Stock Financial Corporation, a major holding company, which owned, among other entities, the East West Bank SA of Luxembourg. Concurrently, OFAC issued three general licenses to mitigate the unintended effects of the new sanctions. (Here, the Department of the Treasury's press release, the Department of State's fact sheet, and the Department of State's press release)

  • The Department of Commerce's Bureau of Industry and Security ("BIS"), added 13 entities to its Entity List for supporting Russia's military through the procurement, development, and proliferation of Russian unmanned aerial vehicles. (Here, press release)

  • NYDF issued a consent order imposing a fine, in the amount of USD 1,250,000.00, against Payoneer, Inc., a money transmitter licensed in the state of New York. (Here) OFAC also announced a settlement with Payoneer, Inc. concerning the same apparent violations in July 2021.

Friday, November 3

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

  • The U.S. Department of State imposed travel restrictions (a type of sanctions) against the former Director of the Department of Procurement at the Kosovo Ministry of Trade and Industry and his two children under Section 7031(c) of the Department of State, Foreign Operations, and Related Programs Appropriations Act, 2023, as carried forward by the Continuing Appropriations Act, 2024. (Here)

  • OFAC imposed asset-freezing sanctions on an individual or her role in laundering and moving funds using virtual currency on behalf of Russian elites under its Russia sanctions program. (Here, the Department of the Treasury's press release, and the Department of State's press release) To find out more about the recently sanctioned person, check out this Chainanalysis blog post.

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