Last month, Germany announced that it will not be approving any new arms exports to Saudi Arabia over the killing of journalist Jamal Khashoggi committed in the Saudi Consulate General, Istanbul (see previous blog).
Yesterday (19 November), Germany’s Minister of Foreign Affairs, Heiko Maas, announced that there will now be a complete ban on all arms sales to Saudi Arabia (including exports that had already been approved by the German government). Furthermore, that Germany has initiated proceedings to impose travel bans on 18 Saudi Arabian nationals allegedly linked to the killing.
Last week (15 November), the US added 17 Saudi Arabian individuals to its Global Magnitsky sanctions list (Executive Order 13818) over “serious human rights abuse resulting from their roles in the killing of Jamal Khashoggi” (see previous blog).
Last week, the US Department of State announced that it has added 26 subentities, including 16 hotels owned by the Cuban military, to the Cuba Restricted List.
That list comprises entities and subentities under the control of the Cuban military, intelligence, and security services or personnel. Direct financial transactions with those entities and subentities are prohibited (bar a few exceptions) on the basis that they would disproportionately benefit those services or personnel at the expense of the Cuban people or private enterprise in Cuba – see the Cuban Assets Control Regulations, 31 CFR §515.209.
Société Générale SA has entered into a 3-year Deferred Prosecution Agreement (DPA) with the USA over sanctions violations; namely, for processing (between 2004 and 2010) US dollar transactions involving countries, persons or entities subject to US sanctions. Under the DPA, SocGen has agreed to pay penalties totalling $1,340,165,000, and to implement remedial measures as required by its regulators. The penalty comprises:
- $717,200,000 to the US Attorney’s Office of the Southern District of New York (Press Release);
- $162,800,000 to the New York County District Attorney’s Office (Press Release);
- $53,900,000 to OFAC (Notice, Enforcement Information, and Settlement Agreement);
- $81,265,000 to the Federal Reserve (Press Release); and
- $325,000,000 to the New York State Department of Financial Services (Press Release).
We reported in September 2018 that SocGen had allocated approximately €1.1 billion ($1.3 billion) to the matter. Link to SocGen Press Release.
OFAC has designated Russia-born, South African national Vladlen Amtchentsev pursuant to Executive Order 13722 for acting for or on behalf of Velmur Management Pte Ltd, a Singapore-based entity previously designated by the US for being involved in the purchase of fuel oil and gasoil for North Korea. As a result, Mr Amtchentsev will now be subject to a US asset freeze and travel ban. See OFAC Notice and US Treasury Press Release.
In November 2015, the US adopted Executive Order 13712, which declared a national emergency in respect of Burundi (US asset freezes and travel bans were imposed on persons contributing to the situation in Burundi).
Last week (16 November 2018), President Donald Trump extended those sanctions for 1 year by continuing the national emergency as declared. See White House press release.
Last week (16 November 2018), the UN Security Council added one individual, Salah Badi, to its Libya sanctions list. As a result, he will now be subject to a UN asset freeze and travel ban. See UN Press Release and Narrative Summary of Reasons for Listing.
On 19 November 2018, the US implemented this UN listing by designating Mr Badi pursuant to Executive Order 13726, see OFAC Notice and US Treasury Press Release.
ACI’s 9th Annual New York Forum on Economic Sanctions will take place on 6 – 7 December 2018 at Andaz Wall Street Hotel, New York.
For further details, see Conference Agenda and Request a Conference Brochure. When registering, use code P10-999-EUSB19 for a 10% online discount.
The EU General Court has upheld Mohamed Mabrouk’s 2017 and 2018 renewed listings under the EU’s Tunisia sanctions, targeting those responsible for the misappropriation of Tunisian state funds – judgment here: T-216/17.
The Court rejected (inter alia) the applicant’s claim that the duration of the judicial proceedings in Tunisia (since the beginning of 2011) infringed his right to be tried within a reasonable time and that on account of its duration the freezing of his EU assets was now producing effects equivalent to a criminal penalty. In October 2017, the same Court rejected Mr Mabrouk’s application to annul his 2015 and 2016 Tunisia sanctions listings – see previous blog.