Monday, Augst 19
This week started with the delisting of an individual from the French national list of sanction targets. On the same day, France added another individual to its national list of sanctions targets under its autonomous counter-terrorism sanctions. (Here)
Tuesday, Augst 20
OFSI updated its Public Officials and Control Guidance with updated links. (Here)
OFAC issued a general license, directly incorporated in the Burma Sanctions Regulations, 31 CFR part 525, to authorize the provision of agricultural commodities, medicine, medical devices, replacement parts and components for medical devices, or software updates for medical devices to individuals whose property and interests in property are blocked pursuant to the Burma Sanctions Regulations. Simultaneously, OFAC revised some sections of Sudan Stabilization Sanctions Regulations to mention OFAC instead of “the Office of Foreign Assets Control” or “the Director of the Office of Foreign Assets Control.” Lastly, OFAC made some small amendments to the Ukraine-/Russia-Related Sanctions Regulations. (Federal Register Notice, and press release)
OFAC imposed non-blocking sanctions on the former Haitian President for drug trafficking under OFAC's counter-narcotics sanctions program. The restrictions are (1) prohibition on any transactions in foreign exchange that are subject to the jurisdiction of the United States and in which this target has any interest; (2) prohibition on any United States financial institution from making loans or providing credit to this target; (3) prohibition on any United States person from investing in or purchasing significant amounts of equity or debt instruments of this target. (Here, and the Department of the Treasury's press release)
💡 Sanctions Expert's take: While such tailored sanctions are good policy options, they introduce challenge to the private sector in implementation since they are not the "usual" blocking sanctions.
DOJ announced a guilty plea of a Venezuelan national who unlawfully exported aircraft parts from the United States to PDVSA through Costa Rica and Spain. (Here)
Wednesday, Augst 21
OFAC has been hard at work modernizing its efforts on several fronts. Here you can see what they have done and what they are doing.
Thursday, Augst 22
There was no major development on this date.
Friday, August 23
Another Friday, another major OFAC/BIS announcement. Here is a breakdown:
OFAC (Here, and press release)
Designated nearly 200 individuals and entities both in Russia and outside its borders—including in Asia, Europe, and the Middle East—whose products and services enable Russia to sustain its war effort and evade sanctions.
Issued five general licenses; and
Issued one FAQ, amended two
Dept. of State (Fact sheet, and press statement)
Imposed blocking sanctions on more than 190 individuals and entities to disrupt sanctions evasion and target entities in multiple third countries and degrade Russia's ability to continue the war.
BIS (press release)
Expanded the scope of the Russia/Belarus Military End User (MEU) and Procurement Foreign Direct Product (FDP) rule and imposed additional license requirements on operation software for computer numerically controlled (CNC) machine tools;
Added 123 entities to the Entity List;
Added more addresses in Hong Kong and Türkiye to the Entity List,
Provided guidance on proper contractual language in sales contracts or other export documents involving items subject to the EAR to prevent diversion to Russia or Belarus.
Recommendation for the week
Our recommendation is to check out our sanctions decision tool and let us what you think about it: Here
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