Monday, September 11
There was no major development on this date.
Tuesday, September 12
France imposed asset-freezing sanctions on one individual under its autonomous counter-terrorism sanctions regime. (Here)
OFAC imposed asset-freezing sanctions on four individuals and three entities under its counter-terrorism sanctions. The sanctioned individuals and entities were allegedly key Hizballah operatives and financial facilitators in South America and Lebanon. (Here, the Department of the Treasury's press release, and the Department of State's press release)
The EU Commission added a new FAQ, FAQ 13, to its list of FAQs related to the EU sanctions against Russia. (Here)
Wednesday, September 13
Australia imposed asset-freezing sanctions on four individuals and three entities under its autonomous Iran sanctions program which targets human rights violations in the country. (Here, and press release)
The EU Council extended Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty, and independence of Ukraine, which imposes asset-freezing sanctions on certain individuals and entities, for another six months through March 15, 2024. (The Decision, and press release)
Thursday, September 14
The UK added seven new product codes to its Common High Priority Items list. (Here)
OFSI update to General Licence INT/2022/2470156 to extend the expiration date of the Schedule 1 Exempt Projects, Sakhalin-2 Project, to 28 June 2024. (Here) OFAC did the same. (Here)
The Departments of State and the Treasury imposed asset-freezing sanctions on 24 individuals and 145 entities, for various reasons all under the U.S. sanctions program against Russia. Some of the designated persons are located outside of Russia in countries like Türkiye, Georgia, and Estonia. Simultaneously, OFAC issued General License 72 to authorize the wind-down of transactions involving certain entities blocked on this day. (Here, the Department of the Treasury's press release, and the Department of State's press release)
Canada imposed asset-freezing sanctions on six individuals responsible for serious human rights violations in Iran under its Iran sanctions regime. (Here, and press release)
Friday, September 15
On the first anniversary of the killing of a Kurdish woman in Iran for not covering her hair "properly", OFSI imposed asset-freezing sanctions on four individuals and one entity in Iran for their involvement in human rights violations, under the UK's sanctions regime against Iran. (Here, and press release)
The EU Council imposed asset-freezing sanctions on four individuals and six entities responsible for serious human rights violations in Iran. (The Decision, the press release, and the relevant Statement)
In an AML-related development, FinCEN imposed a USD 15 million civil penalty against a Puerto Rican bank, Bancrédito International Bank and Trust Corporation. The bank failed to timely report suspicious transactions to FinCEN; failed to establish a due diligence program for correspondent accounts established, maintained, administered, or managed in the United States for foreign financial institutions; and failed to implement and maintain an AML program. (Here)
OFAC imposed asset-freezing sanctions on 25 individuals and four entities in connection with the Iranian regime’s violent suppression of nationwide protests following the death of Mahsa “Zhina” Amini in custody of its ‘Morality Police,’ and the regime’s continued efforts to detain dissenting voices and restrict access to a free and open internet. (Here, the Department of the Treasury's press release, the Department of State's press release, and the Secretary Blinken Remarks)
Recommendations of the Week
Last week FinCEN published a Financial Trend Analysis on patterns and trends contained in Bank Secrecy Act (BSA) reporting on suspected evasion of Russia-related export controls. I highly recommend reading it here.
The REPO Task Force announced that it has mapped USD 280 billion worth of Russian sovereign assets that are immobilized and held in REPO member jurisdictions.
If not already, don't forget to check the EU Commission's Guidance for EU operators about enhanced due diligence on Russia sanctions.
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