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Last week's major developments in sanctions - Sept. 13th to Sept. 17th, 2021

Monday, September 13th

- France added an individual to its list of sanctions targets pursuant to its anti-terrorism sanctions. (Here)

- OFAC designated two already-designated entities under the authority provided by E.O. 14024. The two entities were previously targeted under Non-proliferation of Weapons of Mass Destruction [NPWMD]. (Here)

- The EU Council did some housekeeping in its Ukraine/Russia regime by updating the information associated with several targets under this regime. (Here)

Tuesday, September 14th - An individual who was a resident of the United Arab Emirates and Germany was sentenced to 63 months in prison followed by three years of supervised release for his role in a scheme to obtain military sensitive parts for Iran. (DoJ press release)

- DoJ announced that it brought charges against three individuals in Florida for alleged violation of sanctions and money laundering. (Here)

Wednesday, September 15th

- OFAC added four individuals and two entities to its SDN list pursuant to the Kingpin Act program. (Here, press release)

Thursday, September 16th

- OFAC added five individuals to the SDN list under it Counter Terrorism program for their alleged support of al-Qa’ida in Turkey. (Here, Treasury's press release), Department of State's press release) The Treasury usually tried to avoid using the phrase "secondary sanctions" to describe the risk of being sanctioned for engaging with certain targets; however, in this press release, it used "secondary sanctions" to warn everyone.

Friday, September 17th

- France added two individuals and one entity to its sanctions list under its anti-terrorism sanctions regime. (Here)

- OFAC added several individuals and entities, involved in financing Hizballah and IRGC Qods Force, to the SDN list under its counter terrorisms program. (Here, Treasury's press release, Department of State's press release)

- The President of the United States issued a long awaited Executive Order providing the authority to impose sanctions against those in charge of atrocities in Northern Ethiopia. The Executive Order provided several designation grounds and gave the Secretary of the Treasury a menu-based sanction options for those who would fall under the designation criteria. Concurrently, OFAC issued three general licenses to minimize the unintended effects of the new sanctions. OFAC also published six new FAQs to help the public understand the new sanctions better, in particular the non-applicability of the OFAC 50% rule. (Here, the White House Fact Sheet, Treasury's press release, Department of State's press release)

Recommendation of the week

- This week I would like to recommend the Summer Edition of the Global Sanctions Dashboard of the Atlantic Council filled with interesting information about the recent sanctions.


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