Monday, February 17
There were no major developments on this day.
Tuesday, February 18
The Council of the European Union (the Council) adopted a decision to extend its Zimbabwe sanctions regime for another year, until February 20, 2026. However, the Council removed the only entity listed under this program (Zimbabwe Defence Industries). As such, the EU sanctions regime against Zimbabwe is now limited to restrictions on the sale, supply, transfer or export of arms and equipment for internal repression, and grounds for designations. (Council Decision, and press release)
The Council adopted a decision to align its ISIL and Al-Qaeda sanctions regime with UNSC Resolution 2761 (2024), allowing the continuation of the humanitarian exemption to the ISIL and Al-Qaeda sanctions regime. (Council Decision)
The Council extended its jurisdictional sanctions against non-government controlled areas of Ukraine in the oblasts of Donetsk, Kherson, Luhansk, and Zaporizhzhia for another year, until February 24, 2026. (Council Decision)
Wednesday, February 19
There were no major developments on this day.
Thursday, February 20
OFAC imposed blocking sanctions against two individuals and two entities under its Democratic Republic of the Congo (DRC) sanctions program for their alleged support for the March 23 Movement, a U.S.- and UN-designated armed group that is responsible for human rights abuses in eastern DRC. (Here, the Department of the Treasury's press release, the Department of State's press release)
The U.S. Department of State designated eight international cartels as both Foreign Terrorist Organization (FTO) and Specially Designated Global Terrorist (SDGT), as instructed in Executive Order 14157. Seven out of eight of these international cartels were already designated under different sanctions programs, which means their assets must have been already frozen by the U.S. persons. Being designated as both FTO and SDGT has increased the risks associated with these eight entities by:
Introducing potential criminal liability for knowingly providing “material support” (including financial services) to an FTO pursuant to 18 USC 2339B;
Exposing those that found to have knowingly provided material support to an FTO to risk of civil lawsuits from victims of FTOs’ terroristic acts under the Anti-Terrorism Act; and
Presenting so-called "secondary" sanctions risks for foreign financial institutions that have "knowingly conducted or facilitated any significant transaction on behalf of SDGTs.” (Here, the Department of State's press release, the Department of State's fact sheet)
OFAC launched its new file finder web-based application. The application allows users to search through and efficiently navigate all of OFAC's website content. (Here)
The Multilateral Sanctions Monitoring Team (MSMT) that was established after Russia did not allow the continuation of the mandate of the DPRK panel of expert held its inaugural meeting. The participants underscored their shared determination to fully implement relevant UNSCRs regarding the DPRK. (Here)
Friday, February 21
OFSI published a new general license: General licence – INT/2025/5855272, Membership fees for International Organizations, allowing international organizations to receive certain payments transferred from an account held with Gazprombank. (Here)
Recommendations of the Week
For this week I would like to recommend an an analysis published by Skadden about the direction of travel for sanctions under the new U.S. administration: Political Changes Are Unlikely To Fundamentally Alter Key Sanctions
Yorumlar