Lee Specialities Ltd pleaded guilty last week to a violation of the Canadian Special Economic Measures Act, and agreed to pay a fine of $90,000 Canadian dollars.  This is the first time in over 20 years that a company has been charged with breach of this statute in Canada, and may mark an increase in Canadian sanctions / export control enforcement activity.  The company was charge with violating Canadian export control requirements for goods being shipped to Iran that were valued at $15.

We previously reported on Canada’s imposition of targeted sanctions on Ukraine / Russia.  Canada also has sanctions regimes relating to Iran, North Korea, Syria, Burma, and Zimbabwe.


Like the UK, Australia has an independent reviewer of legislation relating to terrorism, including asset freezing / sanctions provisions. Like the UK’s Independent Reviewer of Terrorism Legislation, the Australian Independent National Security Legislation Monitor reviews the use, effectiveness and proportionality of laws relating to national security and terrorism.

The Monitor (currently Bret Walker SC) was established in 2010 by the Labour government in Australia.  The Monitor’s most recent annual report provides a detailed overview of Australian sanctions legislation, and questions aspects of the efficacy of terrorist financing laws and the way in which terrorist organisations are proscribed in Australia.  The Abbott government has now proposed its abolition on the grounds that all relevant legislation has already been reviewed (although the Monitor’s statutory duties are to review on an ongoing basis whether Australian legislation remains proportionate to the threat of terrorism / national security). The Australian Green party opposes the abolition.

David Anderson’s paper explaining the history and functions of the UK’s Independent Reviewer of Terrorism Legislation is here.  We have previously reported on his recommendations, and on the UK Government’s responses.


ARMSThe UK’s Department of Business Innovation and Skills (‘BIS’), has announced a Call to Evidence from interested parties on the idea of introducing a pre-licence formal register of UK arms brokers, who arrange or facilitate the supply of military equipment between overseas countries.

At present, brokering the export of military equipment between overseas countries is controlled by a system of licensing. The suggestion by BIS is that export licences would only be granted to those parties who had successfully applied to be on the register, and that to be successful, an applicant would need to demonstrate a degree of competence and suitability. In order to promote transparency, it is suggested that the register would be publicly available.

BIS is seeking the views not only of brokers, defence manufacturers, and businesses providing logistics and insurance services that support brokering, but also civil society. The closing date for responses is 30 May 2014, with BIS intending to publish its formal response by September 2014.



The US Treasury Department yesterday added and removed a number of people and companies from its list of ‘Specially Designated Nationals’, designated for their role in “undermining Zimbabwe’s democratic process and institutions or facilitating public corruption through support to the Government of Zimbabwe”.

The USA added a Zimbabwean government official (Tobaiwa Mudede), an Angolan businessman (Sam Pa), a Singaporean lawyer (Jimmy Zerenie), and a Zimbabwe-based entity (Sino Zim Development Pvt Ltd), pursuant to Executive Order (EO) 13469.  The USA removed Mr Rautenbach and companies associated with him from the list (Mr Rautenbach has already been de-listed in the European Union), and nine other individuals (three of whom were dead).  The OFAC list is here and statement here.

Also, we reported last year that two men were being prosecuted in Chicago for lobbying on behalf of US officials to lift sanctions against President Mugabe and others on the US sanctions list, in exchange for the promise of payment. One of these men pleaded guilty earlier this month and will be sentenced.  The other has pleaded not guilty, and his trial is pending.

The European Union’s list of targeted Zimbabwean people and entities is on the ‘sanctions in force’ section of this blog.  Previous Zimbabwe sanctions blog pieces and measures are available by clicking the ‘Zimbabwe’ tab on the blog.


kimOn 15 April 2014, Council Regulation (EC) No 329/2007, the EU Regulation that imposes financial restrictions against North Korea, was amended by :

  • removing one person, Chang Song-taek, formerly designated for being a Director of the Administrative Department of the Korean Workers’ Party, and
  • adding various associated and subsidiary companies of the Korea Ryonha Machinery Joint Venture Corporation.  A list of the additions is clearly set out by UK’s HM Treasury.



195px-european_court_of_justice_insignia-svgWe previously reported here that three Tunisian nationals won their applications to annul their listings before the General Court of the European Union.

The next Tunisian case has also now succeeded, this time brought by Mehdi Ben Ali in Case T-133/12.  The judgment, handed down on 2 April 2014 in Luxembourg is here (only in French). The basis for the judgement is essentially the same as the previous cases concerning Tunisian sanctions.

The European Union’s sanctions relating to Tunisia are on the ‘sanctions in force’ section of this blog.


The Council of the EU has today renewed for another year its sanctions on Burma/Myanmar, and on people and companies said to be “responsible for serious human rights violations” in Iran (which is separate from the list of those said to be connected with Iranian nuclear proliferation).

The EU has also lifted the arms embargo previously imposed on the Republic of Guinea.

The new provisions (published on 15 April 2014) are here and on the sanctions in force section of this blog.  The Council has also published Notices for the attention of everyone re-listed in the annex to these provisions informing them that they have two months in which to challenge their designations in the European court.


The Council of the European Union has today added 4 people to the list of individuals whose assets are frozen in the EU on the grounds that they are “subject to investigation in Ukraine for involvement in crimes in connection with the embezzlement of Ukrainian State funds and their illegal transfer outside Ukraine.”  

They are Serhiy Arbuzov (former Prime Minister of Ukraine), Yuriy Ivanyushchenko, Oleksandr Klymenko (former Minister of Revenues and Charges) and Edward Stavytskyi (Former Minister of Fuel and Energy of Ukraine).

The EU originally imposed these sanctions relating to Ukraine on 21 individuals on 17 March 2014, reported here.  The UK Treasury notice implementing these changes is here.  The new EU Regulation and Decision are here, and on the sanctions in force section of this blog. The Council has also published Notices for the attention of everyone re-listed in the annex to these provisions informing them that they have two months in which to challenge their designations in the European court.