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Last week's major developments in sanctions - July 22nd, 2024, to July 26th, 2024

Monday, July 22

  • The EU Council imposed asset freezing sanctions on four individuals and two entities responsible for serious human rights abuses worldwide, including torture and systematic and widespread sexual and gender-based violence. (Decision, and press release)

  • As the Sanctions (EU Exit) (Miscellaneous Amendments and Revocations) Regulations 2024 came into force 16 May 2024 which amends a number of UK sanctions regimes to, among other things, introduce director disqualification sanctions, OFSI published five updated guidance for its chemical weapons, Guinea, cyber, Syria, and unauthorized drilling activities sanctions regimes.

  • One of the sanctions-related provisions buried in the 21st Century Peace through Strength Act extended the statute of limitation for sanctions violations from five to ten years. After a lot of speculations by the practitioners, OFAC published a guidance. OFAC stated that the 10-year statute of limitations applies to any violation that was not time-barred at the time of its enactment which means, any violation after April 24, 2019, is now subject to the new statute of limitation. (Here)


Tuesday, July 23

  • OFAC imposed blocking sanctions on three individuals for being involved with the Islamic State of Iraq and Syria on the African continent under OFAC's global counter terrorism sanctions program. (Here, the Department of the Treasury's press release, and the Department of State's press release)

  • OFAC imposed blocking sanctions on two individuals and two entities for their roles in the illicit fentanyl trade to the United States. under OFAC's counter narcotics sanctions program. (Here, and the Department of the Treasury's press release)

  • OFAC published another development which implements a provision under the 21st Century Peace through Strength Act. OFAC issued a new reporting requirement for financial institutions holding Russian sovereign assets. (The rule, OFAC's instructions, and press release), U.S. financial institutions must report any sovereign Russian assets by August 2, 2024, provided not reported previously or 10 days from finding out about such assets.


Wednesday, July 24

  • OFAC imposed blocking sanctions on six individuals and five entities under its non-proliferation sanctions regime for being involved in the procurement of items supporting the Democratic People’s Republic of Korea’s ballistic missile and space programs. (Here, the Department of the Treasury's press release, and the Department of State's press release)

  • Australia joined the United States, the United Kingdom, and the European Union in imposing sanctions against Israeli settlers in the West Bank by imposing asset-freezing sanctions on seven individuals and one entity. (Here, and press release)

  • BIS further expanded the Foreign Direct Product rule with respect to Iran to address ongoing concerns regarding Iran’s potential use of U.S. technology in weapons systems. (Here, and Press release)


Thursday, July 25

Friday, July 26

  • The EU Council imposed asset freezing sanctions against nine individuals and one entity responsible for acts that constitute serious human rights violations and abuses in DRC, and for sustaining the armed conflict, instability and insecurity in the Eastern DRC. (Decision, and press release)

  • The EU Council renewed the list of persons, groups and entities subject to restrictive measures with a view to combatting terrorism, added one entity to the list, and delisted one deceased person. (Decision, and press release)

  • OFAC announced a $7,452,501 settlement with State Street. The apparent violations involved invoices that were redated or reissued by Charles River between 2016 and 2020 for certain customers who were subject to Directive 1 of Executive Order 13662, as well as certain payments outside of the applicable debt tenor accepted by Charles River from these customers. (Here)


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