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Last week's major developments in sanctions - October 24th to October 28th, 2022

Monday, October 24

  • France updated its sanctions list by adding one entry related to recently introduced UN sanctions against Haiti. (Kudos to DGT for updating its list very quickly.) Also, this is a reminder that, pursuant to Article L562-1-3 of the France Monetary and Financial Code, the UN designations are in force upon the designation by the UN. The recently listed person, Jimmy Cherizier, was already subject to asset-freezing sanctions in the United States under its Global Magnitsky program.

  • The President of the United States ramped up the existing U.S. sanctions against Nicaragua by issuing Executive Order 14088. The new executive order makes the following changes:

    1. Introduced new grounds for designations, including one that allows designation of a person who operates or have operated in the gold sector of Nicaragua;

    2. Provided the authority to the Secretary of the Treasury to designate more sectors of the Nicaraguan economy as ground for designation;

    3. Granted broad powers to the Secretaries of Treasury and Commerce to impose broad prohibitions on import to the United States, export of U.S. origin goods, and investment activities related to Nicaragua.

  • Concurrently, OFAC designated an individual and an entity, General Directorate of Mines, to the SDN list under the existing framework of sanctions against Nicaragua (i.e. Executive Order 13851). OFAC issued a general license allowing wind-down activities related to the General Directorate of Mines and issued one FAQ to explain the general license it just issued. The Department of State also announced new visa restrictions for more than 500 Nicaraguan individuals and their family members. (The White House Fact Sheet, the Department of the Treasury's press release, the Department of State's press release)

  • The United States Department of State imposed travel bans - a type of sanctions - on three Syrian officials and their immediate family members. (Here)

Tuesday, October 25

  • In two administrative moves, the EU Council extended its sanctions regimes against Burundi and Guinea for another year.

Wednesday, October 26

  • OFAC published two tranches of designations to the SDN list:

    1. Iran Human Rights Designations: 15 individuals and three entities - some of the designations where done by the Treasury under E.O. 13553, 13846, and 13606 while some where done by the State under CATSAA (the Treasury's press release, the State's press release); and

    2. Russia-related and Global Magnitsky Designations: nine individuals and 12 entities (the Treasury's press release, the State's press release)

  • The UK government expanded the scope of its sanctions by introducing the Russia (Sanctions) (EU Exit) (Amendment) (No. 15) Regulations 2022 which came into force on October 29. The new regulation imposes:

    1. Prohibitions on export of goods to Russia that are critical to the functioning of Russia’s economy;

    2. Prohibitions on the import of LNG (starting from January 1, 2023), which is consigned from or originates in Russia, as well as related technical assistance, financial services and funds, and brokering services, which originates in Russia or which is located in Russia, with the intention of the LNG entering the UK;

    3. Expanded the list of revenue generating goods included in Schedule 2E of the regulation;

    4. Prohibitions on the import of gold to the UK; and

    5. Expanded a ban that prohibits loans to certain companies connected with Russia or owned by persons connected with Russia.

Thursday, October 27

  • The EU Council extended the validity of its sanctions against Moldova for another year. (Here) It also removed seven entries that were on the sanctions lists under the EU's sanctions regime. (Here)

  • The EU Commission has been adding new FAQs to its growing number of FAQs about Russia sanctions. The latest update was on October 27 with one question about Depositary Receipts of Russian issuers. Three new FAQs related to the prohibition on the provision of certain services to Russia came a day before. (Here)

Friday, September 28

Recommendation of the week


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