EU lifts travel bans imposed over Mostar attack (10 Feb. 1997)

EU3.jpgThe EU has adopted Council Decision (CFSP) 2018/458, which repeals Common Position 97/193/CFSP. That Common Position imposed EU-wide travel bans on 3 individuals – Ivan Hrkac, Zeljko Planinic, and Bozo Peric – who were identified as “persons having perpetrated violent acts during the incidents in Mostar on 10 February 1997”.

US charges Iranian national with $115m sanctions evasion scheme

US Department of Justice.jpgThe US Department of Justice (Southern District of New York) has announced that Iranian national Ali Sadr Hashemi Nejad has been charged with allegedly participating in a scheme to evade US sanctions against Iran; specifically, “a scheme in which more than $115 million in payments for a Venezuelan housing complex were illegally funnelled through the US financial system for the benefit of Iranian individuals and entities”.

Geoffrey Berman, US Attorney for the Southern District of New York, stated that Mr Nejad had “created a network of front companies and foreign bank accounts [(in Switzerland, Turkey and the British Virgin Islands)] to mask Iranian business dealings in Venezuela and evade US sanctions”.

US inflation adjustment for civil monetary penalties

OFAC2The US Department of the Treasury has published a final rule to adjust its civil monetary penalties (CMPs) for inflation, as required by the Federal Civil Penalties Inflation Adjustment Act of 1990 (as amended). In particular, CMPs within the jurisdiction of certain components of the Treasury Department have been adjusted to the maximum amount required by the 1990 Act (as amended).

New US Executive Order prohibiting transactions with Venezuelan digital currencies

Trump5.jpgUS President Trump has issued a new Executive Order, which takes additional steps to address the situation in Venezuela. In particular, it prohibits US persons from transacting/dealing with “any digital currency, digital coin, or digital token, that was issued by, for, or on behalf of the Government of Venezuela on or after January 9, 2018”. The “Government of Venezuela” is stated as including the Central Bank of Venezuela, as well as the state-owned oil and natural gas company, Petroleos de Venezuela, S.A. (PdVSA).

Acting concurrently, OFAC has released new FAQs related to this Executive Order (which confirms that both the ‘petro’ and the ‘petro-gold’ fall within this Executive Order), as well as a set of new Digital Currency-related FAQs. Furthermore, OFAC has added 4 individuals to its Venezuela sanctions list: Willian Antonio Contreras (‘Vice Minister of Internal Commerce’), Nelson Reinaldo Lepaje Salazar (‘Head of the Office of the National Treasury’), Americo Alex Mata Garcia (‘Alternate Director on the Board of Directors of the National Bank of Housing and Habitat’), and Carlos Alberto Rotondaro Cova (‘Former President of the Board of Directors of the Venezuelan Institute of Social Security’). See OFAC Notice here.

We previously reported that OFAC had published an FAQ relating to US person involvement in the Venezuelan government’s digital currency – the petro – which was launched in February 2018.

EU renews Bosnia & Herzegovina sanctions

EU1.jpgThe EU has renewed its Bosnia and Herzegovina sanctions until 31 March 2019, which imposes asset freezes and travel bans on those deemed to be undermining the sovereignty and territorial integrity of the country, seriously threatening its security situation, or undermining the Dayton/Paris peace agreement (the EU has yet to sanction any individuals/entities under this regime). See Council Decision (CFSP) 2018/459.

New UN Experts Report on DPRK sanctions

UN4The Panel of Experts assigned to the UN Security Council’s DPRK Sanctions Committee has published its Final Report (2018), which offers (inter alia) a series of recommendations for designation.

In respect of North Korea continuing to have “access to the international financial system”, the following individuals and entities have been recommended for designation: Han Hun Il (Edward Han), Ri Ho Nam, Ri Ik (Li Ik), Wang Zhi Guo, Pak In Su, Kim Chang-Hyok and Kim Su-Gwang, as well as ‘International Global System’ and ‘International Golden Services’. The Panel has also reiterated its recommendations in previous reports for the designation of ‘Pan Systems’.

The Report also recommends the ‘Nuclear Weapons Institute’ for designation, on the basis that it is engaged in the nuclear-related programme of the DPRK (it is said to be led by designated person Ri Hong-Sop, and a subordinate company to the designated entity, Munitions Industry Department).

Furthermore, the Panel has recommended that the following 3 individuals should be designated for having violated paragraphs 11 and 14 of UNSC Resolution 2375 (2017) (namely, engaging in the illicit transfer to the DPRK of refined petroleum products by way of ship-to-ship transfers): Shih-Hsien Chen, Boby Julian Akbari (captain of the designated vessel: ‘Billions No. 18’ – see previous blog here) and Wang Songchang (captain of the vessel: ‘Lighthouse Winmore’, which was seized by South Korean authorities earlier this year – see previous blog here).

EU considers new Iran sanctions

EU6The UK, France and Germany have proposed new EU sanctions on Iran over its ballistic missile programme and Syria, to try to ensure that the US continues its commitment to the Iran nuclear deal (JCPOA). EU Foreign Ministers are set to discuss the proposal in Brussels today.

On 12 January 2018, US President Trump agreed a waiver to suspend sanctions on Iran as part of the JCPOA and said that it would be the “last time” he did so unless there was an agreement with the EU  to “fix the deal’s disastrous flaws” (previous blog here). President Trump will next determine whether to waive sanctions on 12 May 2018.

EU implements 2 new UN entries to Somalia sanctions list

EU5.jpgOn 8 March 2018, the UN Security Council added 2 people to its Somalia and Eritrea sanctions list, Ahmad Iman Ali and Abdifatah Abubakar Abdi, for alleged links with Al-Shabaab (previous blog here). The EU has implemented those two new entries by adopting Council Implementing Decision (CFSP) 2018/417 and Council Implementing Regulation (EU) 2018/413.