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Last weeks' major developments in sanctions - Apr. 11th to Apr. 15th, 2022

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

Monday, April 11th

- Twelve individuals came off the French list of sanctions as their period of designation expired.

- OFSI designated Milorad Dodik and Željka Cvijanović, two Bosnian Serb politicians, as sanctions targets under its Bosnia and Herzegovina regime. (Here)

- OFAC added seven individuals and an entity to its SDN list and removed several entries from it. All of the changes were made pursuant to the U.S. Balkans-related sanctions program. (Here, Treasury's press release) The Department of State also took action and designated some of the former officials in North Macedonia and Bosnia and Herzegovina and their immediate family members under Section 7031(c) of the Department of State, Foreign Operations, and Related Programs Appropriations Act, 2022. (Here)

- OFAC designated Kinahan Organized Crime Group and seven members of the group under its Transnational Criminal Organizations program. (Here, Treasury's press release) The Department of State also announced rewards up to $5 million for information leading to each of the arrests and/or convictions of three of them. (Here)

Tuesday, April 12th

- EU Council extended its Human Rights-related sanctions against Iran (COUNCIL DECISION 2011/235/CFSP) till April 13, 2023. The Council also updated the list of designated individuals by removing entries related to 3 deceased persons and updating the information about 25 others. (Here)

- Remember Virgil Griffith? Well, he's sentenced to 63 months in prison after pleading guilty to conspiracy to violate the International Emergency Economic Powers Act and a $100,000 fine. (DoJ press release)

- OFAC issued General License 26 under Russian Harmful Foreign Activities Sanctions program to allow wind-down transactions related to Joint Stock Company SB Sberbank Kazakhstan or Sberbank Europe AG through July 12, 2022. (Here)

Wednesday, April 13th

- One individual came off the French list of sanctions as their period of designation expired.

- OFSI designated 206 individuals today, including the 178 separatists, six oligarchs, close associates and employees, and an additional 22 individuals through its newly enacted urgent procedure for designation. (Press release)

- The U.S. Department of State added nine Nicaraguans to the United States’ Corrupt and Undemocratic Actors list, under Section 353 of the United States–Northern Triangle Enhanced Engagement Act, as amended. The listed individuals are generally ineligible for visas and admission to the United States. (Press release)

- The EU Council amended its decisions which imposed sanctions on Russia and Donetsk and Luhansk regions in order to carve out some humanitarian exceptions. In particular, organizations and agencies acting as humanitarian partners of the EU, such as the ICRC and the UN-specialized agencies, are exempted from the prohibition to make funds or economic resources available to persons and entities designated under the Ukraine territorial integrity regime when the funds or resources are necessary for exclusively humanitarian purposes in Ukraine. In addition, certain clearly defined categories of humanitarian organizations are exempted from the export restrictions and the related prohibition on the provision of services under the Donetsk and Luhansk regime when this is necessary for exclusively humanitarian purposes in the non-government controlled areas of the Donetsk and Luhansk oblasts of Ukraine. Furthermore, under both regimes, organizations not covered by the above exemptions can request Member States to grant a derogation from the same prohibitions when that is necessary for humanitarian activities in Ukraine. (Decisions, press release)

- Australia designated 13 entities including Gazprom Neft, Russian Railways, Alrosa, and United Shipbuilding Corporation. (Here)

Thursday, April 14th

- The U.S. Department of State announced the new head of a recently-reestablished Office of Sanctions Coordination which will oversee work on sanctions and further strengthen cooperation with allies and partners in the use of this critical tool. It will also promote accountability for corruption and human rights abuse and deter and disrupt activities that threaten our national security. (Here) To know more about this office, check section 361 of Consolidated Appropriations Act, 2021.

- OFAC updated the LAZARUS GROUP's entry on the SDN list to include its (or to be more accurate: one of its) Digital Currency Address. (Here)

- OFSI designated two wealthy Russian citizens under its Russia sanctions regime. (Here)

- The UK Parliament passed the Russia (Sanctions) (EU Exit) (Amendment) (No. 8) Regulations 2022 which introduces trade restrictions on:

  • oil refining goods, software and technology;

  • quantum computing and advanced materials goods, software and technology;

  • luxury goods; and

  • the import of iron and steel goods.

- Following the passage of the new regulations, OFSI updated its Russia Guidance. (Here)

- FinCEN issued an advisory on kleptocracy and foreign public corruption, providing typologies and potential indicators of kleptocracy and other forms of foreign public corruption, namely bribery, embezzlement, extortion, and the misappropriation of public assets. (Here)

- BIS identified 10 additional aircraft in likely violation of U.S. export controls, including the first seven Belarusian owned/operated commercial aircraft identified since restrictions on Belarus were tightened via regulation effective on April 8, 2022. The aircraft identified on the list have flown into Russia and/or Belarus in apparent violation of the Export Administration Regulations (EAR). (Press release, BIS list)

- BIS issued a new rule to expands license requirements for Russia and Belarus under the Export Administration Regulations (EAR) to all items on the Commerce Control List (CCL). It also removed license exception eligibility for aircraft registered in, owned or controlled by, or under charter or lease by Belarus or a national of Belarus. Additionally, to recognize partner countries implementing substantially similar export controls on Russia and Belarus, the Department of Commerce published a list of countries excluded from certain U.S. export controls related to foreign-produced items. In this rule, the Department of Commerce adds Iceland, Liechtenstein, Norway, and Switzerland to the list of excluded countries. (Here)

Friday, April 15th

- No major development on this day.


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