OFAC has issued 4 general licences related to EN+ Group, RUSAL, and GAZ Group, which further extend the expiration date of their previous versions from 7 January 2019 to 21 January 2019. See General Licences 13H, 14D, 15C, and 16D. See OFAC Notice and US Treasury Press Release.
At last week’s G20 Summit in Buenos Aires, Argentina (30 November), the President of the EU Council, Donald Tusk, stated that given the recent “escalation in the Sea of Azov” of Russian forces against Ukrainian ships, he was “sure that the EU [would] roll over the sanctions against Russia in December”, namely, the measures targeting the financial, energy and defence sectors of the Russian economy (which are due to expire on 31 January 2019). No reference was made as to whether EU leaders were looking to increase the scope of these sanctions.
The sectoral sanctions were originally introduced in July 2014 (and strengthened in September 2014) for 1 year in response to Russia’s actions “destabilising the situation in Ukraine”. The sanctions have been renewed every 6 months since adoption.
OFAC has announced a $87,507 settlement with Virginia-based Cobham Holdings Inc in order to settle on behalf of its former subsidiary, Aeroflex/Metelics Inc, three violations of the Ukraine-Related Sanctions Regulations. Specifically, between July 2014 and January 2015, Metelics indirectly exported defence components for end-use by Russian defence company Almaz Antey Telecommunications LLC (AAT). At all relevant times, although AAT was not explicitly identified on the SDN List, it was owned 50% or more by Joint-Stock Concern Almaz-Antey, which OFAC had sanctioned on 16 July 2014 (two weeks before Metelics made its first shipment of defence components). See OFAC Notice and Enforcement Information.
OFAC has designated 5 individuals and 4 entities of an “international network through which the Iranian regime, working with Russian companies, provides millions of barrels of oil to the Syrian government. The Assad regime, in turn, facilitates the movement of hundreds of millions of U.S. dollars (USD) to the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) for onward transfer to HAMAS and Hizballah.” The designations were made pursuant to Syria-related Executive Order 13582 and/or terrorism-related Executive Order 13224 (both authorities impose US asset freezes). See OFAC Notice, US Treasury Press Release, Department of State Press Release, and OFAC Advisory: Sanctions Risks Related to Shipping Petroleum to Syria.
The 5 individuals: Muhammad Qasim al-Bazzal; Mohamed Amer Alchwiki; Andrey Dogaev; Rasoul Sajjad; and Hossein Yaghoubi Miab.
The 4 entities: Global Vision Group (Russia-based); Promsyrioimport (Russia-based); Tadbir Kish Medical and Pharmaceutical Company (Iran-based); and MB Bank (Russia-based).
2 individuals, Andriy Volodymyrovych Sushko and Aleksandr Vasilevich Basov, and 1 entity, Ministry of State Security, were designated for committing “serious human rights abuses in the furtherance of the Russian Federation’s forcible occupation or control of territories of Ukraine”. These designations were made under the Support for the Sovereignty, Integrity, Democracy, and Economic Stability of Ukraine Act of 2014, as amended by Section 228 of CAATSA (asset freeze and travel ban imposed).
1 individual, Vladimir Nikolaevich Zaritsky, and 8 entities were designated pursuant to Executive Order (EO) 13685 for being “responsible for advancing Russian interests by operating in the Crimea region of Ukraine” (asset freeze and travel ban imposed). The 8 entities: Joint Stock Company Sanatorium AY-Petri; Joint Stock Company Sanatorium Dyulber; Joint Stock Company Sanatorium Miskhor; Krymtets, AO; Limited Liability Company Garant-SV; Limited Liability Company Infrastructure Projects Management Company; Limited Liability Company Southern Project (this entity was also designated pursuant to EO 13661); and Mriya Resort & Spa.
Yesterday, Russia added 322 individuals and 68 entities to its Ukraine sanctions list (asset freezes) in order to “counter Ukraine’s unfriendly actions towards Russian citizens and legal entities, to ensure that the restrictions imposed by Ukraine on Russian citizens and legal entities are lifted and to encourage the normalisation of bilateral relations”.
According to the press release, the list includes Judges on the Constitutional Court of Ukraine, deputies of the 8th Verkhovna Rada of Ukraine, businesspeople, officials from the Executive Office of the President of Ukraine, heads of executive authorities of Ukraine and large Ukrainian companies, and legal entities controlled by Ukrainian businesspeople. These measures were adopted in accordance with last week’s Presidential Executive Order (see previous blog).
Boris Rotenberg, who is subject to US Russia sanctions, has brought proceedings at the Helsinki District Court against 4 Nordic banks (Nordea, Danske Bank, Handelsbanken, and OP Bank) for breaching his right to equal treatment as an EU citizen by refusing to make payments on his behalf. The banks are said to have refused banking services to Mr Rotenberg because of US secondary sanctions concerns.