On 29 December 2014, the US Office of Foreign Assets Control (“OFAC”) announced the addition of four Russian officials to the Specially Designated Nationals (‘SDN’) list under the Sergei Magnitsky Rule of Law Accountability Act of 2012 (“The Magnitsky Act”).

As previously reported on this blog, the Magnitsky Act allows sanctions not only against those individuals deemed responsible for the death in detention of Russian lawyer, Sergei Magnitsky, but also those involved in human rights violations against anyone seeking to expose illegal activity by Russian officials or seeking to promote human rights in Russia.

The new additions to the list are Victor Grin (the Deputy General Prosecutor of Russia), Apti Kharonovich Alaudinov, Magomed Khozhakhmedovich Daudov and Andrei Alexandrovich Strizhov.

The US Magnitsky sanctions list now contains 34 individuals, including 28 who allegedly played a role in the death of Sergei Magnitsky.



The UK’s Europe Minister reported in October 2014 that the Foreign & Commonwealth Office is “actively reviewing” whether or not the only remaining EU targeted sanctions on Zimbabwe (an asset freeze and travel ban on President Mugabe, Grace Mugabe and Zimbabwe Defence Industries, and an arms embargo) should be renewed by the EU in February 2015, when those measures come up for renewal (see previous post).

The House of Commons’ EU Scrutiny Committee has now requested the Minister, no later than 8 January 2015 (next week) to update the Committee on this review process, on the political situation in Zimbabwe and “the right way forward”, and not to let matters go “down to the wire… as has happened on previous occasions”.  The Committee also said it would have been helpful if the Minister had already “given us some idea of where there has been less progress than she had hoped for, and what improvements she has seen and in which areas”, and noted that: “given recent developments within the ruling ZANU party revolving around the future beyond President Mugabe, whatever decision the Council comes to over restrictions that now apply directly only to the President and his wife, is likely to be controversial”.


The United Kingdom’s House of Commons European Scrutiny Committee has criticised the lack of debate in Parliament on the EU’s sanctions on Russia.

In a summary of its meeting published on 19 December 2014, the Committee stated: “This week we consider two new sets of EU restrictive measures in relation to Ukraine and Russia. Although we clear them from scrutiny, we tag the relevant chapters of our Report to the debate that we have previously recommended on the EU-Ukraine Association Agreement. Last month the Minister asked us to rescind that recommendation as a Backbench Business debate had been scheduled on the floor of the House. We declined to do so. The Minister now tells us that a debate in European Committee is the most appropriate option, and that he has asked his officials to arrange this. We do not agree: we recommend a debate on the floor of the House after serious consideration and with good reason, and it is not for the Minister to contradict the Committee’s view and unilaterally determine the appropriate forum for the debate.”

The House of Lords EU Sub-Committee on External Affairs, which is currently conducting an inquiry into the relationship between the EU and Russia (including hearing evidence from the Europe Minister and from the Russian Minister for Foreign Affairs), including as regards sanctions policy, has made similar comments in the past about the need to debate restrictive measures on the floor of the House.


The EU’s asset freeze on Mr Qadhaf Al-Dam has now been annulled.  As we previously reported (see previous blog), on 24 September 2014 the General Court of the European Union, in its judgement in case T-348/13, annulled those parts of various Council Decisions and Regulations which had added him to the list of people subject to EU restrictive measures in view of the situation in Libya.

The judgment was not appealed to the ECJ within two months and has now come into effect, meaning that Mr Qadaf Al-Dam is no longer subject to an asset freeze.  A notice published by HM Treasury in the UK confirming the position is here.


On 19 December, the EU published Council Regulation (EU) No 1352/2014 and Council Decision 2014/932/CFSP which concern restrictive measures ‘in view of the situation in Yemen’. This implements a new UN Yemen sanctions regime in the EU.

On 7 November 2014, the United Nations Security Council imposed targeted sanctions on the former President of Yemen, Ali Abdullah Saleh, and on two senior Houthi military leaders, for their in involvement ‘in acts that threaten the peace, security or stability of Yemen’ (as we previously reported). They were the first three people to be added to the UN’s new targeted sanctions list relating to Yemen. The US also made the same people subject to US sanctions on 11 November 2014.

The has now implemented these UN sanctions by imposing asset freezes and travel bans in the EU on those who are ‘engaging in or providing support for acts that threaten the peace, security or stability of Yemen’, through actions including obstructing or undermining the successful completion of the political transition, impeding the implementation of the outcomes of the final report of the Comprehensive National Dialogue Conference through violence or attacks on essential infrastructure, or planning, directing or committing acts that violate applicable international human rights law or international humanitarian law, or acts that constitute human rights abuses, in Yemen.

Ali Abdullah Saleh and two senior Houthi military leaders (who are already subject to UN and US sanctions) are now subject to EU sanctions for ‘engaging in acts that threaten the peace, stability and security of Yemen’.

A notice for the attention of those subject to these measures has been published in the Official Journal informing them of their right to submit a request for their listing to be reconsidered to the UN Focal Point for de-listing, or to the Council of the European Union, and to challenge their inclusion before the European court. There is also another notice for the “data subjects” (the same people / entities) under the EU data protection Regulation (EC) No 45/2001 informing them that the data controller is the Council of the EU and giving contact details in relation to the data processing operation.

All EU sanctions currently in force against Yemen can be found on the ‘sanctions in force’ section of this blog. HM Treasury in the UK has published a notice (on 19 December 2014) giving information about this new sanctions regime and its targets.



Canada has announced that it is imposing asset freezing measures and travel bans on 20 more Russian and Ukrainian individuals, and new export restrictions on technologies used in Russia’s oil exploration and extractive sector.  The Prime Minister made the following statement yesterday:

“Canada will not accept the illegal occupation of Crimea and persistent, provocative military activity in eastern Ukraine.  As such, we are once again announcing additional economic sanctions and travel bans against Russian and Ukrainian individuals. We are also imposing new restrictions on the export of technology used in Russia’s oil exploration and extractive sector and further defining existing debt and equity financing prohibitions.

The sanctions we have taken to date, in close collaboration with our allies and partners, are putting real economic pressure on Russia to cease militarism in Ukrainian territory.”

The additional names are here.


obamaOn 19th December 2014, the White House announced that President Obama had signed an Executive Order imposing a new round of sanctions in relation to Crimea.

In summary, the order prohibits U.S. companies or individuals from:

  • exporting or importing any goods, services or technology to or from Crimea,
  • purchasing any real estate or businesses in Crimea,
  • making any new investment in Crimea, or
  • financing or facilitating any transaction by a foreign person in relation to Crimea, that would otherwise be prohibited if performed by a US person.

The Order also freezes any assets in the U.S. of individuals, determined by the U.S. Treasury Department, to be operating in Crimea. Announcing the Executive Order, President Obama stated that it was:

“intended to provide clarity to United States corporations doing business in the region and reaffirm that the United States will not accept Russia’s occupation and attempted annexation of Crimea.”

The Order builds on existing US measures related to Crimea, previously reported on this blog, that can be searched under the USA category.


The EU has today imposed additional sanctions on investment, services and trade with Crimea and Sevastopol ‘in view of the continued illegal annexation of Crimea and Sevastopol’. The new measures, on the ‘sanctions in force’ section of this blog, are Council Regulation (EU) No 1351/2014, which amends Council Regulation (EU) No 692/2014, and Council Decision 2014/933/CFSP which amends Council Decision 2014/386/CFSP. Both measures enter into force tomorrow (20 December 2014).

Sanctions restricting trade with Crimea and Sevastopol were first imposed in June 2014 (as previously reported) and further restrictions were introduced in July 2014 on trade and investment in certain economic sectors and infrastructure projects.

The German Chancellor Angela Merkel said in a news conference today that the EU may consider lifting its sanctions against Russia if Ukraine’s territorial integrity is preserved. She said the EU “will see whether there is any progress in this direction. Then we can move towards lifting the sanctions.”


The previous measures prohibited investment, acquisition, or creation of a joint venture in the transport, communications, energy, and oil, gas and mineral exploration sectors. These prohibitions have been broadened to include:

  • Acquiring or extending ownership in any entity in Crimea and Sevastopol
  • Granting loans or credit or otherwise providing financing to any entity in Crimea or Sevastopol
  • Creating any joint venture in Crimea or Sevastopol
  • Acquiring or extending ownership in real estate located in Crimea and Sevastopol
  • Providing investment services related to any of the sectors listed above

These prohibitions are without prejudice to obligations under contracts concluded before 20 December 2014, if prior notification is provided to a competent authority.


The previous measures prohibited the provision of technical assistance or brokering assistance to investment activities in the transport, communications, energy, and oil, gas and mineral exploration sectors. It was also prohibited to sell, supply, transfer, or export goods and technology in these sectors Crimea and Sevastopol. The new measures further prohibit providing financing or financial assistance to these sectors.


A new ban on providing services directly relating to tourism activities in Crimea and Sevastopol has been introduced. In particular, it is prohibited for cruise ships to call at any ports situated in the Crimean peninsula, except in cases of emergency or under contracts concluded before 20 December 2014 (with the prior authorisation of a competent authority).