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Last week's major developments in sanctions - September 25th to September 29th, 2023

Monday, September 25

  • BIS added 28 entities to the Entity List. Those entities are located across the world, including in China, Russia, Pakistan, Finland, Oman, Germany, and the United Arab Emirates. (Rule, and press release)

Tuesday, September 26

  • OFAC imposed asset-freezing sanctions against ten individuals under the United States Counter-Narcotics sanctions program. (Here, the Department of the Treasury's press release, and the Department of State's press release)

  • The governments of Australia, Canada, New Zealand, the United Kingdom, and the United States today issued joint guidance to industry and academia identifying high-priority items critical to Russian weapons systems and urging specific actions to prevent the diversion of these items to Russia through third countries. The guidance talks about some of the common techniques used to export common high-priority items to Russia. (Here)

Wednesday, September 27

  • OFAC imposed asset-freezing sanctions on two individuals and five entities for their roles in the procurement of sensitive parts for Iran’s unmanned aerial vehicle programe. (Here, the Department of the Treasury's press release, and the Department of State's press release)

  • The United States Department of State announced a visa restriction (a type of sanctions) policy under Section 212(a)(3)C) of the Immigration and Nationality Act for those undermining democracy in Liberia. (Here)

Thursday, September 28

Friday, September 29

  • OFSI imposed asset-freezing sanctions on ten individuals and one entity in Russia. (Here and press release)

  • OFSI updated its Russia sanctions guidance to add additional licensing grounds for the purpose of divestment from Russia. (Here)

  • OFSI issued a general license that would allow the financial institutions to "return" transactions in which a designated bank under Russia or Belarus sanctions is present. The license has a number of conditions and will expire on December 1, 2023. (Here)

  • The EU allowed the broadcasting-related bans against RT Balkan, Oriental Review, Tsargrad, New Eastern Outlook, and Katehon to become effective as of October 1, 2023. (Here)

  • The week ended with the United States Department of State's imposition of visa restrictions (a type of sanctions) on 100 Nicaraguan municipal officials for their role in supporting the Ortega regime’s attacks on human rights and fundamental freedoms and repression of civil society organizations, pursuant to Presidential Proclamation 10309. (Here)

Recommendations of the Week

  • The United States Department of the Treasury's Financial Enforcement Network (FinCEN) had a busy week. They announced an enforcement action, provided new guidance in relation to the forthcoming beneficial owner registration, and requested comments from the public regarding some upcoming changes in the beneficial owner registrations. Check those AML developments here.

  • Banque de France published a working paper called "International Sanctions and the Dollar: Evidence from Trade Invoicing." Check it out here.

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