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Last week's major developments in sanctions - Sept. 27th to Oct. 1st, 2021

Monday, September 27th

- This week started with two enforcement actions against two U.S. subsidiaries of Schlumberger. One of the subsidiaries was found in apparent violations of the Russia sanctions programs (directive 4 restrictions), and the other was found in apparent breach of the former Sudan sanction program of the United States. (Here)

Tuesday, September 28th - No major development on this day.

Wednesday, September 29th

- The United States added seven individuals and one entity to the OFAC SDN list under its global counter terrorism program. (Here, Treasury press release, Department of State press release)

Thursday, September 30th

- OFAC published a non-very-helpful FAQ about donations to a religious site in Iran which is managed by a SDN. (Here) This topic of the FAQ is very interesting because of the constitutional rights of the U.S. persons who would like to donate to the religious site in question. One may argue that OFAC cannot restrict the U.S. persons' rights under the first amendment, if such persons wish to make religious donations.

- OFSI removed five individuals from its list of financial sanctions targets who used to be designated under the Syria regime of the UK. (Here)

- OFAC removed four individuals who used to be targeted pursuant to the Kingpin Act program of the United States. (Here)

Friday, October 1st

- OFAC published an FAQ to clarify about the expiration dates of general license 7C and general license 20B in the Venezuela program. (Here)

Recommendation of the week

- This week I would like to share China's response to the actions of the United States in light of what has been going on in Hong Kong. China's ministry of foreign affairs published a fact sheet (similar to the ones the United States governments publishes) and listed the instances in which China believes the United States has interfered in Hong Kong affairs. (Here)


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