Today, OFAC has removed 10 Colombian entities and 11 Colombian nationals from its counter narcotics trafficking sanctions list. They will no longer be subject to asset freezing measures. See OFAC Notice here.
OFAC has also amended the entries of 4 Mexican nationals appearing on its Kingpin Act sanctions list.
Yesterday, Franco-Swiss cement company LafargeHolcim announced that the examining magistrates in Paris have placed the company’s French component, Lafarge SA, under investigation in relation to payments allegedly made between 2011 and 2014 to sanctioned militant groups, including ISIS, to ensure that its Jalabiya cement plant in Syria continued to operate (the plant had been operated by Lafarge Cement Syria, a subsidiary of Lafarge SA).
In the announcement, Lafarge SA admits that the “system of supervision of its Syrian subsidiary did not allow the company to identify wrongdoings”, but added that the company would “appeal against those charges which do not fairly represent the responsibilities of Lafarge SA”.
In October 2017, we reported that the US had revoked economic sanctions with respect to Sudan under Executive Orders 13067 and 13412 (previous blog).
Yesterday (28 June 2018), OFAC removed from the Code of Federal Regulations the Sudanese Sanctions Regulations as a result of the revocation of certain provisions of Executive Order 13067 and the entirety of Executive Order 13412 on which the Regulations had been based.
In addition, OFAC has amended the Terrorism List Government Sanctions Regulations to incorporate a general licence authorising certain transactions related to exports of agricultural commodities, medicines, and medical devices (the licence had previously only appeared on the OFAC website). See OFAC Notice here.
Today, OFAC has announced the issuance of the Global Magnitsky Sanctions Regulations, which implements the Global Magnitsky Human Rights Accountability Act and Executive Order 13818. OFAC intends to supplement these regulations with a more comprehensive set of regulations, which may include additional interpretive and definitional guidance, general licences, and statements of licensing policy. The regulations will come into force tomorrow (29 June 2018).
US Assistant Secretary of State Wess Mitchell has informed a Foreign Relations Subcommittee that sanctions, pursuant to section 231 of the Countering America’s Adversaries Through Sanctions Act (CAATSA), will be imposed on Turkey for its purchase of S-400 missile systems from Russia.
Section 231 of CAATSA authorises the US President to impose a number of sanctions on those determined to have engaged in a “significant transaction” with the “defense or intelligence sectors of the [Russian Government]”. In late October 2017, the US issued guidance under section 231(d) of CAATSA, naming 39 Russian entities that fit into that category of being part of, or operating for or on behalf of, the defence and intelligence sectors of the Russian Government. The guidance itself did not impose sanctions on the specified entities (see previous blog).
Canada has added 7 people to its targeted sanctions against Myanmar/Burma, by amending the Special Economic Measures (Burma) Regulations. The individuals were sanctioned (asset freezes imposed) for playing a role in the “military operations against the Rohingya in Myanmar’s Rakhine State in August 2017”. See Backgrounder and Press Release.
Earlier this week (previous blog), the EU added the same 7 people to its Myanmar/Burma sanctions: Aung Kyaw Zaw; Maung Maung Soe; Than Oo; Aung Aung; Khin Maung Soe; Thura San Lwin; and Thant Zin Oo.
Following those EU sanctions, the Myanmar/Burma army (Tatmadaw) announced that Maung Maung Soe (Myanmar’s former Major-General) had been permanently removed from his post. He has been subject to Canadian sanctions since February 2018, and US sanctions since December 2017, pursuant to the countries’ Magnitsky laws.
In light of US President Trump’s decision to withdraw from the JCPOA and to re-impose sanctions on Iran, OFAC has revoked Iran-related General Licences H and I, which were issued in connection with the JCPOA.
OFAC has also amended the Iranian Transactions and Sanctions Regulations in order to narrow the scope of the general licences authorising the importation into the US of, and dealings in, Iranian-origin carpets and foodstuffs, as well as related letters of credit and brokering services, to the wind down of such activities through 6 August 2018. The amended Regulation has also issued 2 new general licences authorising the wind down, through 6 August 2018, of transactions previously authorised under General Licence I, and the wind down, through 4 November 2018, of transactions previously authorised under General Licence H.
In addition, OFAC has updated JCPOA-related FAQs 4.3, 4.4, and 4.5. See OFAC Notice here.
Last week (22 June 2018), the Trade and Industry Department of Hong Kong announced that the Hong Kong Government had passed the United Nations Sanctions (Democratic People’s Republic Of Korea) (Amendment) Regulation 2018, which implements the latest UN sanctions against North Korea; namely, the measures contained within UN Security Council Resolutions 2270, 2321, 2371, 2375 and 2397.