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Last week's major developments in sanctions - September 26th to September 30th, 2022

Monday, September 26

  • Four individuals came off the French sanctions list as their six-month long designation period ended. All of those individuals were targeted under French counter-terrorism sanctions regime.

  • OFAC designated Diana Kajmakovic, a state prosecutor in Bosnia and Herzegovina, pursuant to Executive Order (E.O.) 14033 for being responsible for or complicit in corruption or the undermining of democratic processes or institutions in the Western Balkans. (Here, Treasury's press release, State's press release)

  • OFAC issued FAQ 1090 which explains whether the U.S. persons send remittances to Cuba using digital payments. The short answer is yes, provided certain conditions are met. (Here)

  • The UK imposed blocking sanctions on 92 additional targets. (Here, press release)

  • OFAC announced two separate settlement agreements against two subsidiaries of Credit Agricole. Both subsidiaries (one located in Switzerland and the other in Monaco) caused other U.S. persons to violate sanctions by providing services in USD to residents of comprehensively sanctioned countries. (Here)

Tuesday, September 27

  • OFSI imposed a monetary fine on Hong Kong International Wine and Spirits Competition Ltd in the amount of GBP 30,000 for violations of Russia/Ukraine sanctions regime in the UK. Hong Kong International Wine and Spirits Competition Ltd engaged in receiving bottles of wines from a designated person as well as paying that designated person. (Here)

  • OFAC published a short report on the number of license applications it received in the fourth quarter of 2021and that of the granted licenses for food, medicine, or medical devices to be exported to Iran. OFAC received 17 license requests and issued four during this period. (Here)

  • The Security Council Committee established pursuant to resolution 2140 (2014) (Yemen) added two entries to its Sanctions List of individuals and entities.

Wednesday, September 28

Thursday, September 29

  • France added nine entries to its list of sanctions targets under the country's counter-terrorism sanctions. (Here)

  • In a non-sanctions development, FinCEN issued the final rule which requires most corporations, limited liability companies, and other entities created in or registered to do business in the United States to report information about their beneficial owners to FinCEN. This has been a major gap in the U.S. anti-money laundering framework. (Here)

  • OFSI updated its Libya Guidance. (Here)

  • OFAC designated an international network of companies involved in the sale of Iranian petrochemicals and petroleum products to end users in South and East Asia. (Here, Treasury's press release, State's press release)

  • The United States unsealed an indictment against three individuals, including Oleg Deripaska for violating the U.S. sanctions as well as other alleged wrongdoings. (Here)

Friday, September 30

  • Following the "referendum" in four regions of Ukraine to join Russia, OFAC added hundreds of entities and individuals to its sanctions lists. (Here, Treasury's press release, State's press release)

  • OFAC published a new FAQ reminding everyone that supporting Russia following its sham referenda, purported annexation, and continued occupation of the Kherson, Zaporizhzhya, Donetsk, and Luhansk regions of Ukraine exposes a person to the U.S. sanctions.

  • The UK also took action following the "referendum" in those four regions by adding an individual to its sanctions lists (here) and by expanding the prohibition on services to Russia. The expanded prohibitions include the following sectors: IT consultancy services, architectural services, engineering services, advertising services, transactional legal advisory services, and auditing services. (Here)

  • OFAC issued a "Compliance Communique" about the instant payment services. (Here)

  • OFAC reissued Libyan Sanctions Regulations which included more interpretations and general licenses.

  • OFAC announced a settlement with Tango Card for $116,048.60. Tango Card failed to take the IP address and the emails addresses it had into consideration. As a result, Tango Card provided services to parties located in jurisdictions that are subject to comprehensive U.S. sanctions. (Here)

Recommendations of the week

  • Next week founder, Amir Fadavi, will speak at ACI Forum on Digital Assets and Compliance about Russia sanctions and the sanctions screening for digital assets companies. If you are interested in the conference, please email us at

  • Last week, the International Court of Justice, continued hearings on the Iran's case against the United States. For more information (including to read the oral arguments), check out this page.


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