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Last week's major developments in sanctions - April 24th to April 28th, 2023

Monday, April 24

  • This week started with new sanctions against Iran.

    1. OFSI imposed asset-freezing sanctions on four IRGC commanders to its sanctions list under its Human Rights regime. (Here, press release)

    2. The EU Council imposed asset-freezing sanctions on eight individuals and one entity for their involvement in serious human rights violations in Iran. (Council's Decision, press release)

    3. OFAC imposed blocking sanctions on five senior officials in Iran pursuant to various authorities under OFAC's sanctions program against Iran. (Here, the Department of the Treasury's press release, the Department of State's press release)

  • The EU Council imposed asset-freezing sanctions on 25 individuals and eight entities under the Union's sanctions regime against Syria. The sanctioned persons were involved in the drug trade that benefits the Assad regime in Syria. (Council's Decision, press release)

  • The EU Council imposed asset-freezing sanctions on two individuals and one group affiliated with ISIL that operate mainly in Mozambique under its counter-terrorism sanctions regime. (Council's Decision, press release)

  • OFSI updated its Russia Guidance to reflect the provisions in Russia (Sanctions) (EU Exit) (Amendment) Regulations 2023. (Here)

  • OFAC imposed asset-freezing sanctions on three individuals for providing support to the Democratic People’s Republic of Korea through illicit financing and malicious cyber activity. (Here, the Department of the Treasury's press release) In addition, the Department of Justice unsealed indictments against those sanctioned individuals. (Here) For more information check out this post by Chainanalysis. Finally, the Department of State announced rewards for information leading to the arrest of those individuals. (Here)

Tuesday, April 25

  • France added three individuals to its list of sanctioned persons under the country's counter-terrorism sanctions program. (Here)

  • OFAC announced a settlement with British American Tobacco p.l.c. a UK-based company in the amount of $508,612,492. (Here, press release) The Treasury's action was accompanied by that of the Department of Justice, which also announced a settlement with British American Tobacco. (Here)

  • In an interesting case related to Viktor Vekselberg, a Russian SDN, a New York attorney pleaded guilty to participating in a scheme to make approximately $3.8 million in U.S. dollar payments to maintain six real properties in the United States that were owned by Vekselberg. (Here)

  • The EU Council updated one of the entities under its Iran sanctions program and removed one. (Here)

Wednesday, April 26

  • OFAC published an updated version of the Iranian Transactions and Sanctions Regulations and the Western Balkans Stabilization Regulations. (Here) Note that the updates were technical rather than substantive.

  • In a non-sanctions-related development, FinCEN assessed a $1.5 million on the Kingdom Trust Company, for lack of compliance controls and failure to report certain transactions. (Here)

  • The Department of State imposed travel restrictions (a type of sanction) on a senior official in Sri Lanka and his wife pursuant to Section 7031(c) of the Department of State, Foreign Operations, and Related Programs Appropriations Act, 2023, due to his involvement in a gross violation of human rights. (Here)

  • The Department of the Treasury published a fact sheet on the recently published 2023 De-risking Strategy. The fact sheet discusses key findings and recommendations to address the issue of de-risking. (Here)

  • The Security Council ISIL (Da’esh) and Al-Qaida Sanctions Committee imposed asset-freezing sanctions and travel restrictions on two individuals. (Here)

Thursday, April 27

Friday, April 28

  • The EU Council extended the asset-freezing sanctions for 92 persons and 17 entities until April 30, 2024, and until October 29, 2023, concerning one person and one entity under its Myanmar sanctions program. (Council's Decision)

  • Australia's Department of Foreign Affairs and Trade (DFAT) is soliciting public comments on proposed amendments to the Autonomous Sanctions Regulations 2011. If you have comments, you can send them to DFAT by May 19, 2023. (Here)

  • OFSI issued one new general license for legal services under its Belarus sanctions regime and updated an existing one related to Law Enforcement and Regulatory Authorities Asset Recovery under its Russia sanctions regime.

  • The EU Council adopted a new framework for targeted restrictive measures (a.k.a. sanctions) that provides the EU with the possibility of imposing sanctions against persons responsible for supporting or implementing actions that undermine or threaten the sovereignty and independence of the Republic of Moldova, as well as the country’s democracy, the rule of law, stability or security. (Council's Decision, press release)

The Recommendation of the Week

  • There has been a lot of talk about how to counter Russia's effort to evade sanctions in the past few months. To that end, delegations of the U.S., EU, and UK visited Astana last week to talk about countering the evasion of sanctions and export controls imposed on Russia for its war against Ukraine. Check the relevant press release here.

  • Furthermore, Treasury Deputy Secretary Wally Adeyemo and other officials convened deputies of the G7 Enforcement Coordination Mechanism to bolster the enforcement of multilateral sanctions and export controls. Check the relevant press release here.

  • Some reports have emerged pointing out the U.S. is seeking to impose a nearly total export ban on Russia, a move that has been pushed back against by the EU. El País had a piece about it. Check it out here.

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