Further US Iran sanctions for “human rights abuses, censorship and enhanced monitoring”

US Treasury BuildingYesterday, OFAC designated, pursuant to Executive Order (EO) 13553, 2 Iranian entities – Ansar-e Hizballah and Evin Prison – for “committing serious human rights abuses on behalf of the Government of Iran”, and 3 “leaders” of Ansar-e Hizballah (Abdolhamid Mohtasham, Hossein Allahkaram, and Hamid Ostad).

OFAC also designated the Iran-based Hanista Programing Group, pursuant to EO 13606, for operating information or communications technology that “facilitates monitoring or tracking that could assist or enable serious human rights abuses by or on behalf of the Government of Iran”.

OFAC also designated, pursuant to EO 13628, 2 people Abolhassan Firouzabadi and Abdolsamad Khoramabadi, for “engaging in censorship activities that prohibit, limit, or penalize the exercise of freedom of expression or assembly by citizens of Iran”, and Abdulali Ali-Asgari (Director General of Islamic Republic of Iran Broadcasting (IRIB)), for “acting for or on behalf of an entity engaged in such censorship activities”.

See OFAC Notice and Treasury press release.

EU foreign ministers tell Commission to be ready to protect EU interests after US JCPOA withdrawal

In the latest step taken by the EU to preserve the JCPOA nuclear agreement after the US decided to withdraw from it earlier this month, the EU Foreign Affairs Council has told the Commission to be ready to act whenever European interests are affected by the US’ decision.

This follows a unanimous agreement by EU leaders on 16 May that the EU should remain in the JCPOA so long as Iran is fully committed to it, and a commitment from the EU on 18 May that it would work to mitigate the impact of US sanctions on European companies doing business with Iran (EU press release here).

Ukraine adds to and renews its sanctions on media organisations

Ukraine has imposed sanctions on online publication Ekonomicheskie Izvestia and its publisher Media Innovation Group LLC. The sanctions are wide-ranging, and include an asset freeze, restrictions on access to telecommunications networks, and restrictions on trading.

It has also extended its sanctions against several Russian media organisations, including Russia Today, for 3 years.

21 June Brexit sanctions event – VENUE CHANGE TO SAVOY

Due to a wonderfully large number of positive responses we have changed the London venue for this Brick Court Chambers event to a larger one.  It will be very topical – the new Sanctions & AML Act 2018 became law last week which enacts the new legal framework for sanctions post Brexit. Topics and speakers for this event are here.   The venue is now:

Savoy Hotel – Lancaster Room

London WC2R 0BP (River Entrance on Savoy Place off Victoria Embankment)

21 June 2018

4.15pm registration for 4.30pm start

4.30pm – 7pm panel discussion

7pm reception in the lovely River Room

If you haven’t already done so, please confirm your place by emailing marketing@brickcourt.co.uk and please let us know if you can no longer attend.

US drafts Security Council resolution for more asset freezes on South Sudan government

The US has drafted a UN Security Council resolution that, if passed, would impose asset freezes on a number of government ministers and officials in South Sudan. It is reported that they have been targeted for obstructing attempts to secure peace in South Sudan and provide humanitarian assistance to citizens.

The targets include Minister of Information Michael Lueth, Defence Minister Kuol Manyang Juuk, and governor of Bieh State Koang Rambang. In November last year, Russia poured cold water on the idea of imposing new asset freezes or an arms embargo on South Sudan. The US was unsuccessful in its attempt to impose an arms embargo in December 2016.

2 new OFAC FAQs on Ukraine & Russia sanctions

OFAC has published 2 new FAQs relating to US sanctions on Ukraine & Russia. They are here.

The first FAQ addresses the ability of US persons to receive payments of principal and interest from blocked people listed in General Licences 12C, 14, and 15.  It states that this is authorised, provided the loan or bond existed before 6 April 2018 and the payments are in accordance with the pre-existing loan or bond contract. It adds that the General Licences would also generally authorise the receipt of accelerated payments or voluntary prepayments, in the circumstances set out above and where they are consistent with maintenance or wind-down activities.

The second FAQ says that whether OFAC will impose sanctions on a foreign entity for paying dividends to a blocked person, where that company is not itself blocked under the 50% rule, depends on whether OFAC views the transaction as significant (see FAQs 542545579, and 589). Where the payment of dividends is done in such a way as to provide no economic benefit this will not be considered significant.

EU Syrian sanctions renewed

The EU has extended its Syria sanctions until 1 June 2019, in view of the “continuing repression of the civilian population of Syria”. They were also updated to remove 2 deceased individuals. See Council Implementing Regulation (EU) 2018/774, Council Decision (CFSP) 2018/778, EU press release, and UK OFSI Notice.

EU planning new sanctions against Venezuela

In a strongly worded statement issued today, EU Foreign Ministers agreed to impose additional sanctions against targeted individuals in Venezuela. The Foreign Ministers expressed concern about the credibility of the re-election of President Maduro on 20 May 2018 and promised that “the EU will act swiftly, according to established procedures, with the aim of imposing additional targeted and reversible restrictive measures, that do not harm the Venezuelan population, whose plight the EU wishes to alleviate.”

It is expected that the new measures will be adopted on 25 June. They will supplement the earlier EU sanctions against Venezuela described here.