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Last week's major developments in sanctions - March 4th, 2024, to March 8th, 2024

Monday, March 4

  • The United Kingdom's Foreign, Commonwealth & Development Office published Post-Legislative Scrutiny Memorandum: Sanctions and Anti-Money Laundering Act 2018. The long report, provides a summary and a preliminary assessment of the provisions and implementation of the Sanctions and Anti-Money Laundering Act 2018. (Post-legislative scrutiny is an inquiry by a parliamentary select committee into how a new law has worked in practice since it came into force.)

  • The United Kingdom's government published a guidance document about doing business in Iran. (Doing business in Iran: trade and export guide) The guidance provides an overview of sanctions and trade restrictions concerning Iran, followed by the opportunities and the risks associated with doing business with Iran. Overall, the guidance encourages UK businesses to take advantage of the commercial opportunities compliantly.

💡I did not expect this guidance from the UK's government while it has been increasingly critique of Iran's government crackdown on human rights and its regional influence.


  • The U.S. President issued Executive Order 14118 which terminated the previously-declared emergency with respect to the situation in Zimbabwe and as such terminated the U.S. sanctions program against Zimbabwe. As a result, OFAC delisted 121 entries from its SDN list. Also, OFAC removed 12 of the targets under the terminated Zimbabwe program and re-designated them under the Global Magnistky sanctions program. Additionally, OFAC designated two individuals, including the First Lady of the Zimbabwe, under the Global Magnitsky sanctions program. (Here, the Department of Treasury's press release, the Department of State's press release)

💡 Both the EU and UK still have sanctions regimes against Zimbabwe.

💡 I found the termination of the Zimbabwe sanctions program and moving some of the sanctions targets to the the Global Magnitsky sanctions program a welcomed sanctions cleanup by the U.S. government.

  • OFAC published a new FAQ to explain the difference between the prohibition of 'imports of Diamond Jewelry and Unsorted Diamonds of Russian Federation origin' and Diamond Jewelry and Unsorted Diamonds exported from the Russian Federation.' (Here)


Tuesday, March 5

  • The EU Council extended the validity of Council Decision 2014/119/CFSP of 5 March 2014 concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in Ukraine for another year until 6 March 2025. (Only three individuals are targeted by the asset-freezing sanctions provided under this Decision.) (Council Decision 2024/828)

  • OFSI removed Igor Viktorovich Makarov from its list of sanctions targets. He was not sanctioned by the United States or the European Union. The reason he was sanctioned by the UK was that he "has been involved in supporting the government of Russia by working as a director or equivalent through his role as president of ARETI International Group, an entity operating in the Russian energy sector - a sector of strategic significance to the government of Russia." I could not find why he was delisted; nor could find any sanctions against ARETI International Group.

  • OFAC imposed blocking sanctions on two individuals and five entities under its Cyber sanctions program due to their role in "developing, operating, and distributing commercial spyware technology used to target Americans, including U.S. government officials, journalists, and policy experts." (Here, the Department of Treasury's press release, the Department of State's press release)


Wednesday, March 6

  • OFAC imposed blocking sanctions on two entities and identified two vessel as target under its counter terrorisms sanctions program for their role in helping IRGC and its support of Houthis. (Here, the Department of Treasury's press release, the Department of State's press release)

  • DOJ, BIS, and OFAC issued their third joint compliance note. This note is about the obligations foreign-based individuals and entities have to comply with U.S. sanctions and export control laws and the risks of exposure that they face for non-compliance. Even though nothing new is in the this compliance note, it is an important one since it directly address non-U.S. persons and explains some of the risks to them. (Here)


Thursday, March 7

  • The National Security Division of the Department of Justice published and updated version of its voluntary self-disclosure enforcement policy. (Here)

Friday, March 8
Recommendations for the week

  • For this week I have two podcast suggestions:

🎙 Episode 39 of FinCast - Juan Zarate invited Katya Hazard and me to his podcast to talk about two years of Russia sanctions (here); and

🎙 Sanctions+ (Here)

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