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Last weeks' major developments in sanctions - Apr. 25th to Apr. 29th, 2022

Updated: May 10, 2022

For a detailed post about Russia-related sanctions developments you can check: Special Edition - New Sanctions Against Russia 🇷🇺

Monday, April 25th

  • If you ever wonder about organizing a conference in North Korea about blockchain technology, think twice! After sentencing Virgil Griffith to 63 months in prison and a USD 100,000 fine, the United States unsealed charges against Alejandro Cao De Benos, 47, a citizen of Spain, and Christopher Emms, 30, a citizen of the United Kingdom because they assisted Griffith in organizing the Cryptocurrency and Blockchain Conference in North Korea. (Here)

  • OFAC published an enforcement action notice related to Toll Holdings Limited. Toll Holdings Limited (“Toll”), an international freight forwarding and logistics company headquartered in Melbourne, Australia, has agreed to pay $6,131,855 to settle its potential civil liability for 2,958 apparent violations of multiple OFAC sanctions programs. (Here) From the language of the notice, it seems that OFAC likes the idea of introducing "hard controls" which disabled the possibility of entering certain locations in its freight management system. Indeed, disabling the possibility of entering some values can avoid potential violations down the road.

  • OFAC issued Ukraine-/Russia-related General License 13R (authorizing the wind Down of certain transactions necessary to divest or transfer debt, equity, or other holdings in GAZ Group) and General License 15L (authorizing the wind down of transactions involving GAZ Group). OFAC also published FAQ 592 to further explain the scope of GL 15L.

Tuesday, April 26th

  • No major development on this day.

Wednesday, April 27th

  • OFSI issued General License - INT/2022/1679676. The GL carved out activities of Crown Relevant Organisations from the scope of prohibitions provided certain conditions are met. It also permitted certain activities related to asset recovery. (Here)

Thursday, April 28th

  • The Monetary Authority of Singapore ("MAS") issued a document titled "Strengthening AML/CFT Name Screening Practices." As a result of some of its thematic inspections MAS observed some good practices, areas for improvement, and illustrative examples and it has shared them in this document. (Here)

Friday, April 29th

  • The UK Parliament passed Russia (Sanctions) (EU Exit) (Amendment) (No. 9) Regulations 2022. (Here) The Amending Regulations introduced new restrictions on the provision of certain internet services to or for the benefit of designated persons In particular:

  1. A person who provides a social media service must take reasonable steps to prevent content that is generated directly on the service, or uploaded or shared on the service, being encountered by a user of the service in the UK.

  2. A person who provides an internet access service must take reasonable steps to prevent a user of the service in the UK from accessing an internet service provided by a designated person.

  3. A person who provides an app store must take reasonable steps to prevent a user of that store from downloading or otherwise accessing an internet service provided by a designated person.

  • OFAC did some administrative jobs:

  1. Amended and reissued the Ukraine-Related Sanctions Regulations, 31 C.F.R. part 589, and renaming the regulations the Ukraine-/Russia-Related Sanctions Regulations;

  2. Updated several FAQs related to the Ukraine-/Russia-Related Sanctions Regulations; and

  3. Modified some of the unique identifier numbers (UIDs) of the entries on the SDN, and Non-SDN list

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