On 20 October 2014, the Council of the European Union issued a press release announcing 18 new names to be added to the list of those sanctioned in relation to the EU’s restrictive measures against the Syrian regime. The new measures target fourteen persons said to be linked to the violent repression of the civilian population, as well as two persons and two entities providing support to the Syrian regime. The sanctions impose an asset freeze and travel ban on all those listed.

The full Decision and list of names will be published tomorrow in the EU’s Official Journal.

In addition to the targeted measures above, the Council has reached a political agreement to impose a ban on exporting jet fuel and relevant additives to Syria. This has been done in an attempt to curb the indiscriminate air attacks that have been inflicted on the civilian population. The legal acts supporting this decision have yet to be formally adopted.


On 16 October 2014, the United States Department of Treasury announced new sanctions related to Syria.

The latest measures target a senior Syrian Air Force Intelligence Officer (Qusay Mihoub), believed to be responsible for serious human rights abuses in the region.

The sanctions also list 12 individuals and entities deemed to be supporters and officials of the Syrian regime. These include one Lebanese company (DK Group Sari) and its General Manager, two Cypriot companies (Piruseti Enterprises Ltd. and Frumineti Investments Ltd.) and their directors, four state-controlled Syrian banks (Agricultural Cooperative Bank, Industrial Bank, Popular Credit Bank, and Saving Bank), and two senior Syrian government officials (Khodr Orfali and Kamal Eddin Tu’ma).

By these measures, the designated individuals and entities will henceforth be subject to a freeze on any assets held within US jurisdiction. US citizens and persons within the US are also prohibited from doing business with any listed parties.


On 17 October 2014, the United States Department of Treasury’s Office of Foreign Assets Control (OFAC) issued a short guidance paper on the provision of humanitarian assistance by not-for-profit non-governmental-organisations. The guidance is intended to clarify the reach of US sanction legislation and its enforcement with respect to the provision of humanitarian assistance.

In the paper, OFAC reaffirms its commitment to facilitating humanitarian assistance, and refers in brief to a number of possible situations faced by NGOs when providing assistance abroad. The guidance confirms that providing assistance within countries not subject to comprehensive sanctions (e.g Yemen, Iraq, Somalia, South Sudan, or Côte d’Ivoire), even if this includes to individuals or entities under the command or control of a Specially Designated National (SDN), is not per se prohibited.

OFAC urges NGOs to employ due diligence to avoid SDNs from profiting from aid in the area, however does recognise that some humanitarian assistance may unintentionally end up in the hands of sanctioned groups or persons. In such cases, OFAC provides the reassurance that ‘[s]uch incidental benefits are not a focus for OFAC sanctions enforcement’.

Finally, the guidance states that, should an NGO find itself in the position where dealing with an SDN is necessary to ensure the provision of urgent humanitarian assistance, such issues should be addressed on a case-by-case basis through discussion with OFAC.


On 15 October 2014, the United Kingdom created two new statutory instruments relating to Sudan and South Sudan.

The first order, the Sudan (Sanctions) (Overseas Territories) Order 2014, gives effect in specified overseas territories to sanctions imposed on Sudan by various United Nations Security Council resolutions. The sanctions imposed include an arms embargo and asset freezes and travel bans against individuals designated under the regime. The territories to which the order extends are: Anguilla; British Antarctic Territory; British Indian Ocean Territory; the Cayman Islands; the Falkland Islands; Montserrat; Pitcairn, Henderson, the Ducie and Oeno Islands; St Helena, Ascension and Tristan da Cunha; South Georgia and the South Sandwich Islands; the Sovereign Base Areas of Akrotiri and Dhekelia in the Island of Cyprus; the Turks and Caicos Islands and the Virgin Islands.

The Sudan and South Sudan (Restrictive Measures) (Overseas Territories) Order 2010, the Sudan (United Nations Measures) (Overseas Territories) Order 2005, and the Sudan (Restrictive Measures) (Overseas Territories) (Amendment) Order 2004 have now been revoked.

The second order, the South Sudan (Sanctions) (Overseas Territories) Order 2014, gives effect in specified Overseas Territories to sanctions against South Sudan adopted by the European Union in Council Decision 2014/449.

Both orders enter into force on 5 November 2014.



On 15 October 2014, the Council of the European Union issued two press releases declaring the alignment of certain third countries with the EU’s most recent restrictive measures related to the situation in Ukraine.

The first release declared that Montenegro, Iceland, Albania, Liechtenstein, Norway, and Ukraine have agreed to align their national policies with the EU following Council Decision 2014/658/CFSP of 8 September 2014. This decision, as we reported earlier, amends the listing criteria found in Council Decision 2014/145/CFSP of 17 March 2014, which allows for restrictive measures against those seen to be undermining or threatening the integrity, sovereignty and independence of Ukraine. The amendment also adds 24 persons to the sanctions list.

The second release declared that Montenegro, Iceland, Albania, Norway and Ukraine shall also align themselves with Council Decision 2014/659/CFSP of 8 September 2014. This decision amended Council Decision 2014/512/CFSP of 31 July 2014 to expand the list of entities subject to sanctions to include certain Russian financial institutions, and defence and energy companies. The amendments also tighten restrictions on Russian access to EU capital markets and the export of dual-use goods.

A full list of sanctions in effect relating to the conflict in Ukraine can be found in the ‘EU sanctions in force’ section of this blog.


On 15 October 2014, the Council of the European Union issued a press release declaring the alignment of eight non-Member States to the EU’s latest decision on restrictive measures against the Republic of Moldova.

The former Yugoslav Republic of Macedonia, Montenegro, Iceland, Albania, Liechtenstein, Norway, Ukraine, and Georgia have all agreed to align their national policies with Council Decision 2014/381/CFSP of 23 June 2014, which amended Council Decision 2010/573/CFSP of 27 September 2010 concerning restrictive measures against the leadership of the Republic of Moldova to extend the existing measures until 31 October 2014.

As we reported earlier, the EU had previously agreed to extend the restrictive measures, which consist of a travel ban on nominated Moldovan leaders, until 27 September 2014. The latest decision further extends this period by one month.

Links to all the current European sanctions (including those against Moldova) are on the ‘EU sanctions in force’ section of this blog.


We reported last year that two men were being prosecuted in the federal District Court in Chicago for engaging in “public relations, political consulting and lobbying” US officials to lift sanctions against President Robert Mugabe and others on the US Zimbabwe sanctions list, in exchange for the promise of payment. We also reported that Mr Ben Israel pleaded guilty in April 2014 and was sentenced to 7 months imprisonment.

A US federal jury has now (on 10th October) convicted Gregory Turner of one of three counts of lobbying on behalf of Zimbabwean government officials. He was acquitted of two charges of failure to register with the US Attorney General as an agent of a foreign power, and found guilty of a conspiracy count by acting on behalf of President Mugabe’s regime by organising a delegation of politicians to try to end the US sanctions first imposed against Zimbabwe in 2003.

The position of the US Office of Foreign Asset Control (OFAC) is that lobbying is not covered by an OFAC licence authorising the provision of legal services to people on a US sanctions list, and is therefore a criminal offence. Although OFAC licences authorise “representation of persons before any federal or state agency with respect to the imposition, administration, or enforcement of U.S. sanctions against such persons”, OFAC does not consider Congress or State legislatures to be “agencies”.


There are 3 seminars on sanctions in London over the next few days:

1) Royal United Services Institute, “People, Policy and Putin: the long-term effects of sanctions on Russia”. 9am, 15th October.  Details here. Maya Lester is speaking.

2) Business for New Europe, “The impacts of EU sanctions against Russia on the City of London”. 8.30am, 16th October.  Details here.   Maya Lester is speaking.

3) Sweet & Maxwell Human Rights Conference. 22nd October, all day.  Details here.  Michael O’Kane and Maya Lester speaking on the sanctions panel.