The Council of the European Union held a special meeting on (inter alia) Ukraine yesterday.  Its conclusions state that it “stands ready” to take “further significant steps in the light of the evolution of the situation on the ground”.  The Council has requested the European Commission urgently to “undertake
preparatory work together with the Action Service and present proposals for consideration within a week”, and has asked the Commission to include in its proposal “a provision on the basis of which every person and institution dealing with the separatist groups in the Donbass will be listed.”

The Council stated that the “stage three” sanctions adopted at the end of July (see previous post) “are having a visible impact on the Russia’s economy”.  All sanctions relating to Russia are on the “sanctions in force” section of this blog.

The Council also announced that it has appointed Federica Mogherini (currently the Italian foreign minister) as the High Representative for Foreign Affairs and Security Policy of the European Union, replacing Catherine Ashton (who has held that position since November 2009).


The USA has today imposed sanctions on companies and individuals that are “engaged in proscribed activities” and “providing support to illicit Iranian nuclear activities”.  The State Department press release states that these actions “underscore U.S. resolve to enforce sanctions as the P5+1 and Iran work toward a comprehensive solution to address the international community’s concerns over Iran’s nuclear program”.

The new US sanctions take the following form:

(1) Sanctions on 4 companies pursuant to Executive Order (E.O.) 13382 for engaging in or attempting to engage in “activities that have materially contributed to, or posed a risk of materially contributing to, the proliferation of WMD or their means of delivery”. The Department of State’s designations comprise Iran-based entities engaged in efforts to support the development of nuclear weapons, or elements of Iran’s program that could be used to produce nuclear weapons. The 4 companies are the Organization of Defensive Innovation and Research, the Nuclear Science and Technology Research Institute, Jahan Tech Rooyan Pars, and Mandegar Baspar Kimiya Company.  Under the same Executive Order, the US Treasury Department has also designated Mohammad Javad Imanirad and Arman Imanirad for acting for or on behalf of designated Iranian company, Aluminat, and Nefertiti Shipping for its ties to the Islamic Republic of Iran Shipping Lines (IRISL).

(2) Sanctions pursuant to the Iran Freedom and Counter-Proliferation Act of 2012 (IFCA) on Goldentex FZE, a UAE-based company said to be “involved in providing support to Iran’s shipping sector”. IFCA mandates, among other things, the imposition of sanctions on individuals and companies determined to have knowingly transferred to or from Iran significant goods or services used in connection with the energy or shipping sector of Iran, including the National Iranian Oil Company or the National Iranian Tanker Company (NITC).

(3) Sanctions on Italy-based Dettin SpA pursuant to the Iran Sanctions Act of 1996 (ISA), as amended by the Iran Threat Reduction and Syria Human Rights Act of 2012 (TRA). Dettin SpA is said to have been “knowingly providing Iran’s petrochemical industry with goods and support whose value exceeded $250,000”.  The press release states that “although the JPOA authorizes Iran to export petrochemicals, providing goods, services, and support for the maintenance or expansion of Iran’s domestic production of petrochemicals is not within the scope of sanctions relief under the JPOA and, therefore, remains sanctionable.”

The new US Treasury Department sanctions are, in addition, as follows:

(1) Treasury designated two entities and three individuals tied to Iran’s energy industry pursuant to E.O. 13645.  They are Faylaca Petroleum, Abdelhak Kaddouri, Muzzafer Polat, and Seyedeh Hanieh Seyed Nasser Mohammad Seyyedi.  It also identified 6 vessels pursuant to this authority, connected with Lissome Marine Services LLC.
(2) Treasury designated one entity (Asia Bank) pursuant to E.O. 13622 for its provision of material support to the Central Bank of Iran in connection with the purchase or acquisition of U.S. dollar bank notes by the Government of Iran.
(3) Treasury identified 5 Iranian banks that are subject to sanctions under E.O. 13599, which blocks the property and interests in property of the Government of Iran and Iranian financial institutions. They are
Khavarmianeh Bank, Ghavamin Bank, Gharzolhasaneh Resalat Bank, Kish International Bank, and Kafolatbank.
(4) Treasury designated 4 entities and one individual pursuant to E.O. 13224 in connection with Iran’s support for terrorism.  They are Meraj Air, Caspian Air, Sayyed Jabar Hosseini, Pioneer Logistics and Asian Aviation Logistics.


On 27 August 2014 the UN Security Council unanimously adopted a resolution to expand targeted sanctions on militia groups and their supporters in response to the escalation of hostilities in Libya.

UNSC Resolution 2174 (2014) calls for an immediate ceasefire between all parties to the conflict, and expands the already existing sanctions regime, which permits asset freezes, travel bans, and arms embargos on listed individuals.

The expanded sanctions are intended to target those who lend support to the violent militia groups fueling Libya’s ongoing conflict. The resolution states that sanctions may now also apply to ‘individuals and entities determined by the Committee to be engaging in or providing support for other acts that threaten the peace, stability or security of Libya, or obstruct or undermine the successful completion of its political transition’.

The list of individuals to be subject to these extended sanctions has yet to be determined.


On August 27 2014 the US Treasury Department designated Muhammad Iqbal and Asma Money Exchanges as Specially Designated Global Terrorists (SDGTs) for their affiliation to the Lashkar-e-Tayyiba (LT) terrorist group. LT is a Pakistan-based terrorist group that has taken credit for the series of attacks that took place in Mumbai in 2008.

The new sanctions are designed to target the leadership and financial networks of LT. As SDGTs, all property and interests in the US under the control or possession of Iqbal or Asma will be blocked, and all US persons are prohibited from engaging in transactions with either party. Asma, which has been determined to be owned or controlled by Iqbal, is seen as a critical financial supplier of LT’s terrorist activities.


On 4 August 2014 the UN Security Council amended the entries for 2 people on the Al-Qaida Sanctions Committee’s list of persons, groups and entities to whom UN restrictive measures apply and on 15 August it added 6 new people.  The restrictive measures freeze their funds and economic resources and prohibit granting, selling, supplying or transferring technical advice, assistance or training related to military activities to any of the individuals and entities concerned, whether directly or indirectly.

On Thursday (21st August) the European Union implemented those amendments by means of Commission Implementing Regulation (EU) No 914/2014 of 21 August 2014 which amends Annex I to Regulation (EC) No 881/2001, and published a notice for the attention of the people affected.

The 6 people that have been added are Abdelrahman Mouhamad Zafir al Dabidi al Jahani, Hajjaj Bin Fahd al Ajni, Abou Mohamed al Adnani, Said Arif, Abdul Mohsen Abdallah Ibrahim al Charekh and Hamid Hamad Hamid al-‘Ali.  The notice states that those people may submit at any time a request to the UN Ombudsperson for the Al-Qaida Sanctions Committee, together with any supporting documentation, for the decision to include them in the UN list referred to above, to be reconsidered.  There is no court with jurisdiction to review decisions of the UN Security Council or its Sanctions Committees, but the General Court of the European Union reviews European Union measures implementing UN listing decisions (see e.g. previous posts on the Kadi litigation in Europe); the notice draws that possibility (and a process for submitting observations to the EU) to the attention of listed people. The mandate of the UN Ombudsperson for that committee was extended in June – see previous post.

The EU’s sanctions that relate to terrorism, Al-Qaida and the Taliban are on the “sanctions in force” section of this blog.


We reported last year that 2 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.

One of them, Prince Asiel Ben Israel, has today been sentenced to 7 1/2 months in prison. He had pleaded guilty to trying to persuade US government officials, including an Illinois state senator and two US representatives from Chicago, to push for the lifting of the sanctions imposed in 2003 on President Robert Mugabe and other Zimbabwean government officials.  His co-defendant C Gregory Turner has pleaded not guilty and is awaiting trial.

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”.


We reported yesterday that the UN Security Council blacklisted 6 people said to be connected with the Islamic State and Nusra Front, including Abu Mohammed Al-Adnani.

Today the US Department of State has designated Abu Mohammed al-Adnani as a Specially Designated Global Terrorist under Executive Order (E.O.) 13224.  Born Taha Sobhi Falaha in Syria, he is the said to be the “official spokesman for and a senior leader of ISIL, and ISIL’s main conduit for the dissemination of official messages, including ISIL’s declaration of the creation of an Islamic Caliphate.”

The State Department press release explains that the consequences of designation include a prohibition against US persons engaging in transactions with Mr al-Adnani, and the freezing of all property and interests of Mr al-Adnani that are in the United States, or come within the United States or the possession or control of US persons.

Yesterday’s UN designation means that he will be added to the UN 1267/1989 al-Qa’ida Sanctions list, requiring all member states to implement an asset freeze, a travel ban, and an arms embargo against Mr al-Adnani.


The United Nations Security Council yesterday adopted a resolution that blacklists 6 people who will be subject to an international travel ban, asset freeze and arms embargo, who are said to be connected with or providing support for the Islamic State and Nusra Front (both organisations blacklisted by the Security Council). 

The Security Council resolution states that it “deplores and condemns in the strongest terms the terrorist acts of ISIL (Islamic State) and its violent extremist ideology, and its continued gross, systematic and widespread abuses of human rights and violations of international humanitarian law.”

The resolution condemns the recruitment of foreign fighters and expresses readiness to blacklist people financing or facilitating travel of foreign fighters. It expresses concern that revenue generated from oilfields captured by both groups is being used to organize attacks.  The resolution condemns any direct or indirect trade with Islamic State or Nusra Front and warns such moves could lead to sanctions. It asks UN experts – charged with monitoring violations of the council’s al Qaeda sanctions regime – to report in 90 days on the threat posed by Islamic State and Nusra Front, and on details of their recruitment and funding.