Monday, September 16
On the second anniversary of the killing of Mahsa Jina Amini, the Australian Government imposed asset-freezing sanctions on additional five Iranian individuals under Australia's autonomous sanctions against Iran. The sanctioned individuals were senior security and law enforcement officials that have been complicit in the violent repression of protests in Iran. (Here, and press release)
The UK's Export Control Joint Unit published a notice to exporters regarding the recently expanded trade restrictions on Iran. As a result of the Iran (Sanctions) (Amendment) Regulations 2024 which came into effect on September 13, UK persons may not export additional goods and technology that are significant to Iran’s military development and its production of Unmanned Aerial Vehicles (UAVs) and missiles program. (Here)
OFAC imposed blocking sanctions on four Georgian individuals for human rights violation in Georgia under the United States' global Magnitsky sanctions program. (Here, the Department of the Treasury's press release, and the Department of State's press release)
OFAC imposed blocking sanctions on five individuals and one entity associated with the Intellexa Consortium for their role in developing, operating, and distributing commercial spyware technology under the United States' cyber sanctions program. (Here, the Department of the Treasury's press release, and the Department of State's press release)
Tuesday, September 17
There was no major development on this day.
Wednesday, September 18
OFAC imposed blocking sanctions on 12 individuals in Iran who have been involved in repression the people of Iran since the killing of Mahsa Jina Amini, two years ago, under the United States' Iran sanctions program. (Here, the Department of the Treasury's press release, and the Department of State's press release)
Thursday, September 19
France imposed asset-freezing sanctions on two individuals under its autonomous counter-terrorism sanctions program. (Here)
OFAC imposed blocking sanctions on one individual and three entities, including two banks for being involved in illicit payment mechanisms between Russia and the DPRK. These designations were made under both North Korea and Russia sanctions programs of the United States. (Here, and the Department of State's press release)
OFSI published an updated Iran guidance to incorporate additional restrictions introduced in the Iran (Sanctions) (Amendment) Regulations 2024. (Here)
Friday, September 20
There was no major development on this day.
Recommendation for the week
The first recommendation for this week is to join FinCEN Virtual Info Session on Beneficial Ownership Reporting, on Wednesday, Sept. 25, 2024, at 2 p.m. ET at www.youtube.com/@fincentreasury
The second recommendation of the week is not a recommendation. Instead, it is a summary of some of the major developments in the sanctions world in the first two weeks of September, since I could not publish the weekly updates during that period:
On September 13, OFAC published a new rule that will give it more flexibility with respect to targets that are blocked pending investigation. As a result, OFAC won't be bound by publishing such name on the Federal Register and it will have other ways like reaching out to financial institutions to block certain assets pending investigation. (Here)
On September 12, BIS issued a final rule making changes to the provisions in the Export Administration Regulations related to BIS’s policies and practices regarding voluntary self-disclosures and to the Guidance on Charging and Penalty Determinations in Settlement of Administrative Enforcement Cases (BIS Penalty Guidelines). (Here)
On September 11, OFAC published an Interim Final Rule to Extend Recordkeeping Requirements from Five to 10 Years, effective March 12, 2025. (Here) You can provide comments through November 11, 2024.
On September 10, OFAC designated some Iranian entities for allegedly transferring arms to Russia, including Iran Air. (Here)
On September 9, BIS updated its Guidelines for Preparing Export License Applications Involving Foreign Persons (Deemed Exports/Reexports). (Here)
On September 4, OFAC published an alert, "Russian Attempts to Evade Sanctions Using New Overseas Branches and Subsidiaries," to warn foreign jurisdictions and financial institutions about Russia’s attempts to evade sanctions by opening new overseas branches and subsidiaries of Russian financial institutions. (Here)
Last but not least: DO NOT FORGET to file your Annual Blocked Property Report with OFAC by September 30.
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