UK issues export control guidance on 2017 changes to information security products

ECOThe UK’s Export Control Joint Unit (ECJU) has issued guidance on the 2017 changes to ‘information security’ products contained within Category 5 Part 2 of the consolidated list of strategic military and dual-use items that require export authorisation.

US designates 9 ISIS-affiliated groups and leaders

US Department of State.jpgThe US Department of State has designated 3 ISIS-affiliated groups as Specially Designated Global Terrorists (SDGTs), pursuant to section 1(b) of Executive Order (EO) 13224, and as Foreign Terrorist Organisations (FTOs), pursuant to section 219 of the Immigration and Nationality Act. The groups are ISIS-West Africa, ISIS-Philippines, and ISIS-Bangladesh.

The State Department has also designated 4 other ISIS-affiliated groups and 2 ISIS-affiliated leaders as SDGTs, pursuant to section 1(b) of EO 13224. The groups are ISIS-Somalia, Jund al-Khilafah-Tunisia, ISIS-Egypt, and the Maute Group, and the individuals are Mahad Moalim and Abu Musab al-Barnawi.

As a result, asset freezes and travel restrictions have been imposed. Links to OFAC Notice, State Department Press Release, updated list of Designated ISIS Branches and Individuals, and Terrorism Designations FAQs.

EU considers sanctions against Burma, Cambodia and Maldives

EU2Yesterday, the EU adopted conclusions on the situation in Myanmar/Burma, Cambodia and Maldives.

In respect of Myanmar/Burma (particularly Rakhine State), the EU condemned the “ongoing widespread, systematic grave human rights violations committed by Myanmar/Burma military and security forces”. It also invited the High Representative to make proposals for an extension to the existing arms embargo, as well as targeted sanctions to be imposed against senior military officers of the Myanmar armed forces (Tatmadaw) responsible for “serious and systematic human rights violations”. Links to the EU conclusions on Myanmar/Burma and the press release.

In respect of Cambodia, the EU decided that it might consider targeted measures if the “continu[ed] deterioration of democracy, respect of human rights and the rule of law” in Cambodia failed to improve. It particular, the EU urged the Cambodian Government to “stop using the judiciary as a political tool to harass and intimidate political opponents, civil society, labour rights activists and human rights defenders”. Links to EU conclusions on Cambodia and the press release.

In relation to Maldives, the EU called on the competent Maldivian institutions to “lift immediately the state of emergency and restore all constitutionally guaranteed rights”. It also decided that if the current situation failed to improve, targeted measures might be considered. Links to EU conclusions on Maldives and the press release.

OFAC targets international Libyan-oil smuggling network

US Treasury Building.jpgPursuant to Executive Order 13726, OFAC has sanctioned 6 people, 24 entities and 7 vessels for “threatening the peace, security, or stability of Libya through the illicit production, refining, brokering, sale, purchase, or export of Libyan oil or for being owned or controlled by designated persons” (US travel restrictions and asset freezes imposed). See OFAC Notice and Treasury press release.

The 6-sanctioned individuals (Maltese nationals Darren Debono, Gordon Debono, Rodrick Grech and Terence Micallef, Libyan national Fahmi Ben Khalifa, and Egyptian-Maltese citizen Ahmed Ibrahim Hassan Arafa), were each designated for their involvement in the “smuggling of petroleum products from Libya to Europe”.

Of the 24-designated entities, 21 companies were sanctioned for being “owned or controlled” by Darren and Gordon Debono, whilst the remaining 3 entities were designated for being “involved in the illicit exploitation of crude oil or any other natural resources in Libya, including the illicit production, refining, brokering, sale, purchase, or export of Libyan oil”.

UN Security Council renews Yemen sanctions until 26 Feb. 2019

UNSC.jpgThe UN Security Council has unanimously adopted Resolution 2402 (2018), which renews until 26 February 2019 the arms embargo, travel bans and asset freezes against those “threatening peace and security in Yemen”. UN press release here.

An alternate draft resolution, tabled by the UK, was defeated by a vote of 11 in favour to 2 against (Russia (veto) and Bolivia), with 2 abstentions (China and Kazakhstan). That draft would have highlighted “specific non-compliance by Iran”, namely, the Panel of Experts’ finding that Iran had failed to take the necessary measures to prevent the supply, sale or transfer of short-range ballistic missiles and unmanned aerial vehicles to the then Houthi-Saleh alliance, breaching para 14 of UNSC Resolution 2216 (2015). Following the draft resolution’s defeat, the US Ambassador to the UN Nikki Haley warned of unilateral (although unspecified) action against Iran.

EU sanctions 2 Syrian Ministers & adds 1 entry to ISIL and A-Q sanctions list

EU1Today, the EU has sanctioned 2 Ministers of the Syrian Government “for being responsible for the violent repression against the civilian population in Syria, benefiting from or supporting the regime, and/or being associated with such persons” (travel bans and asset freezes imposed). The individuals are Mohamed Mazen Ali Yousef, Minister of Industry, and Imad Abdullah Sara, Minister of Information. See Council Implementing Decision (CFSP) 2018/284 and Council Implementing Regulation (EU) 2018/282. Those legal acts also update the information relating to 5 previously sanctioned individuals. EU press release here and UK OFSI Notice here.

In a separate action, the EU has added a French national, Fabien Clain, to its ISIL (Da’esh) and Al-Qaeda sanctions list (asset freeze imposed). See Council Decision (CFSP) 2018/283 and Council Implementing Regulation (EU) 2018/281. UK OFSI Notice here.

Further US & EU sanctions against N Korea

North Korea Flag and Missiles.jpgUSA:

OFAC has sanctioned 1 individual (Tsang Yung Yuan; a Taiwanese citizen), 27 entities, and 28 vessels located, registered, or flagged in North Korea, China, Singapore, Taiwan, Hong Kong, Marshall Islands, Tanzania, Panama, and Comoros. It is said that this action “will significantly hinder North Korea’s ability to conduct evasive maritime activities that facilitate illicit coal and fuel transports, and limit the regime’s ability to ship goods through international waters”. See OFAC Notice, Treasury press release and Press Briefing by Treasury Secretary Steven Mnuchin.

All 27-sanctioned entities are shipping and trading companies, 2 of which were designated for being “owned or controlled” by Mr. Yuan (who was designated in the present action for coordinating “North Korean coal exports with a Russia-based North Korean broker”, as well as being involved “other sanctions evasion activities”).

In addition to these measures, OFAC has issued a global shipping advisory to “put everyone on notice of North Korea’s illicit maritime tactics and underscore the significant sanctions risk of engaging in maritime business with North Korea”.


Today, the EU increased its sanctions against North Korea in order to align itself with UN Security Council Resolution 2397 (2017) – see previous blog here. As a result, the following measures were transposed through the adoption of Council Decision (CFSP) 2018/293 and Council Regulation (EU) 2018/285:

(i) Cap on the export of all refined petroleum products to North Korea, from 2 million barrels to 500,000 barrels per year;

(ii) Ban on imports from North Korea of food and agricultural products, machinery, electrical equipment, earth and stone, and wood;

(iii) Ban on exports to North Korea of all industrial machinery, transportation vehicles, and expansion to all iron, steel and other metals;

(iv) Further maritime restrictive measures against vessels where there are reasonable grounds to believe that they have been involved in the breach of UN sanctions; and

(v) Requirement to repatriate all North Korean workers abroad within 24 months.

Under UNSC Resolution 2397 (2017), the prohibition on the export of crude oil had already been introduced in the EU on 16 October 2017 (previous blog here), and the 16 individuals and 1 entity that were sanctioned had been implemented on 8 January 2018 (previous blog here). On 22 January 2018, the EU also imposed unilateral sanctions against a further 17 individuals (previous blog here). EU press release here.

EU renews sanctions on Belarus

The EU has extended its sanctions on Belarus until 28 February 2019, which consist of an arms embargo and targeted asset freezes and travel bans against 4 people. The 4 people are suspected of being involved in the unresolved disappearances of 2 opposition politicians, 1 businessman, and 1 journalist in 1999 and 2000. It has also prolonged a derogation allowing the export of biathlon equipment to Belarus, such as sporting rifles, subject to prior authorisation.

See Council Decision (CFSP) 2018/280 and Council Regulation (EU) 2018/275. EU press release here.