Following a review of its nuclear sanctions on Iran and several judgments of the General Court and the Court of Justice annulling listings on those measures, the EU has confirmed that a number of entities no longer appear on the EU’s sanctions lists (see previous blogs here and here). They are:
- Moallem Insurance Company
- Petropars Operation & Management Company
- Petropars Resources Engineering Ltd
- Iran Aluminium Company
- Iran Liquefied Natural Gas Co.
- Hasseatic Trade Trust & Shipping (HTTS) GmbH
- Naser Bateni
- North Drilling Company
- Good Luck Shipping Company LLC
In addition, the EU has confirmed that it has deleted from its sanctions lists the following entities:
- Bank Saderat PLC (London) (see previous blogs on the EU deletion of Bank Saderat Iran)
- Neka Novin
- West Sun Trade GMBH
- Oil Industry Pension Fund Investment Company (OPIC)
See Regulation (EU) 2017/77 implementing Regulation 267/2012 and Decision 2017/83 amending Decision 2010/413/CFSP. HM Treasury’s notice is here.
At his last press conference as President, Barack Obama commented on US sanctions on Russia and their possible future under Donald Trump. Responding to Trump’s suggestion that he may lift sanctions on Russia in return for their cooperation on nuclear disarmament, President Obama noted that the sanctions had been imposed because of Russia’s actions in Ukraine and that it would not be in the US’s interests to link them to the separate issue of nuclear disarmament. He reiterated his position, which is also that of the other G7 nations (see previous blog), that they should be lifted only if Russia ends its actions in Ukraine. A link to the full press conference transcript is here.
The EU has published a notice addressed to 50 people and 7 entities listed on its targeted Russia sanctions, saying that it intends to maintain their sanctions listings with new statements of reasons. The sanctions target people and entities said to be responsible for undermining the territorial integrity of Ukraine. The notice is here. The people affected may submit a request to the Council to obtain the intended statements of reasons for their designation before 23 January 2017, and at any time a request to the Council that the decision to include and maintain them on the list should be reconsidered. The next review is 7 February 2017.
OFAC has designated President of Republika Srpska Milorad Dodik, one of the two entities that make up Bosnia and Herzegovina, under US sanctions targeting people who obstruct the Dayton Accords. In the US Treasury’s press release, Dodik is said to have violated the rule of law by defying the Constitutional Court of Bosnia and Herzegovina, posing “a significant threat to the sovereignty and territorial integrity of Bosnia and Herzegovina”.
The EU has de-listed 5 vessels from its sanctions on North Korea, implementing a UN decision to de-list them at the end of last year. The vessels were listed for being operated or managed by listed entity Ocean Maritime Management Company.
See Commission Implementing Regulation 2017/80 amending Council Regulation 329/2007 and Council Decision 2017/82 amending Council Decision 2016/849.
President Obama has eased US sanctions on Sudan, in recognition of Sudan’s improved cooperation with the US including on counter-terrorism, improvements to humanitarian access, and the reduction in its military activity in conflict areas such as Darfur. Under a new general licence published by the US Treasury, several prohibited transactions have been authorised, including transactions involving persons in Sudan, transactions involving property in which the Government of Sudan has an interest, and imports to and from Sudan. The relevant sanctions provisions will be fully revoked on 12 July 2017 provided that the government of Sudan sustains this conduct.
OFAC has published a fact sheet and a new set of FAQs, which note that this action does not authorise transactions prohibited under US sanctions on Darfur or South Sudan. The details and FAQ are here.
President Obama has extended all US sanctions on Russia that were imposed in response to the Ukraine crisis by 1 year, until March 2018 (see notice here). The sanctions were due to expire had the President not renewed the national emergency first declared in respect of Russia’s actions in Ukraine in March 2014.
The leaders of the G7 countries have consistently stated that sanctions on Russia should continue until Russia complies with its obligations under the Minsk peace agreement (see previous blog). However, over the weekend President Elect Donald Trump raised the prospect of lifting sanctions against Russia sooner, saying that while he would keep sanctions against Russia in place “at least for a period of time…if you get along and if Russia is really helping us, why would anybody have sanctions if somebody’s doing some really great things?”. In particular, he appeared to tie lifting sanctions to an agreement from Russia to reduce its stockpile of nuclear arms. In November last year, Russia suspended nuclear cooperation between Russia and the US in response to the sanctions (see previous blog).
OFAC has announced two settlement agreements relating to violations of US sanctions on Iran and Cuba.
Aban Offshore Limited
Aban has agreed to pay $17,500 for violating US sanctions on Iran in 2008 when its Singapore subsidiary ordered oil rig supplies from the US, with the intention of re-exporting them from the UAE to a rig in Iranian territorial waters. OFAC determined that Aban did not voluntarily self-disclose the violation, but that it constituted a non-egregious case. In mitigation, OFAC also noted that Aban displayed substantial cooperation with OFAC’s investigation, including by conducting its own internal investigation into potential prior violations of sanctions. OFAC’s enforcement notice is here.
An individual & Alliance for Responsible Cuba Policy Foundation
OFAC has issued a $10,000 fine to an individual acting in his personal capacity and Alliance, on whose behalf the individual also acted. They are said to have violated US sanctions on Cuba by engaging in unauthorised travel-related transactions during business travel to Cuba in 2010 and 2011. Although OFAC found the individual’s conduct to have been wilful, it noted that the violations appeared to cause minimal harm to US sanctions objectives. OFAC’s enforcement notice is here.