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Last weeks' major developments in sanctions - Mar. 14th to Mar. 18th, 2022

This issue only contains the non-Russia related developments. For the timeline of all the sanctions measures against Russia and Belarus since February 21st to March 20th check out this link : Special Edition - New Sanctions Against Russia

Monday, March 14th

- No major development on this day.

Tuesday, March 15th

- One individual came off the French list of sanctions as its 6-month designation period expired.

- The UK's parliament passed the Economic Crime (Transparency and Enforcement) Act 2022. (The Act, Press release)

- OFSI designated nine individuals pursuant to its Cyber sanctions regime. (Here) When you look at the OFSI's notice you will see that the UK government used the new urgent designation authority that was given to it in the recently passed Economic Crime Act 2022 just hours before the designation.

Wednesday, March 16th

- The U.S. Department of State announced that it will use the authority under Section 212(a)(3)(C) of the Immigration and Nationality Act, to restrict the issuance of visas (a type of sanction) for those believed to be responsible for, or complicit in, undermining the democratic process in Somalia. (Here)

Thursday, March 17th

- Two individuals and one entity came off the French list of sanctions as its 6-month designation period expired. They were all designated under the french autonomous counter-terrorism sanctions.

- OFAC designated 1 individual and 9 entities related to Alain Goetz, the African Gold Refinery in Uganda, that were involved in the illicit movement of gold valued at hundreds of millions of dollars per year from the Democratic Republic of the Congo (DRC). (Here, press release)

Friday, March 18th

- OFAC designated seven individuals and two entities under its counter narcotics program. (Here, press release) At the same time, the Department of State offered a reward of up to $10 million for information leading to the arrest or conviction of one of the recently designated individuals. (Here)

- EU Councils extended the sanctions against Bosnia and Herzegovina till 31 March 2024. (Council Decision, press release)

Recommendation of the week

- By now, we all have seen the catchy headlines about the "seizure" of yachts belonging to Russian oligarchs. However, asset freezing (what sanctions do) are not seizure. For asset forfeiture of seizure there should be legal proceedings, while there are no such proceedings when someone is designated as a sanctions target. Sanctions are political tools that are used by the executive branches of the government (sometimes as prescribed by the legislative branches), seizures or forfeitures on the other hand, are handled by the judicial branches. The other main difference is the ownership of assets: when an individual is sanctioned, he or she will remain the owner of his or her assets. If you want to read more about this please check this article on Politico: Confiscating a Russian oligarch’s luxury condo requires much more than political bluster

Happy Nowruz to those who are celebrating it. 🌷


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