OFAC adds 17 people to Global Magnitsky sanctions over Jamal Khashoggi killing

US Treasury Building2Yesterday, OFAC added 17 Saudi Arabian individuals to the US Global Magnitsky sanctions list (Executive Order 13818) for “serious human rights abuse resulting from their roles in the killing of Jamal Khashoggi” at the Saudi Arabian Consulate in Istanbul, Turkey, on 2 October 2018 (US asset freezes and travel bans imposed). See OFAC Notice, US Treasury press release, and Department of State press release.

The 17 individuals: Saud al-Qahtani; Maher Mutreb; Salah Tubaigy; Meshal Albostani; Naif Alarifi; Mohammed Alzahrani; Mansour Abahussain; Khalid Alotaibi; Abdulaziz Alhawsawi; Waleed Alsehri; Thaar Alharbi; Fahad Albalawi; Badr Alotaibi; Mustafa Almadani; Saif Alqahtani; Turki Alsehri; and Mohammed Alotaibi.

OFAC amends DRC sanctions regulations

US Treasury BuildingToday, OFAC issued an amendment to the Democratic Republic of the Congo Sanctions Regulations to implement Executive Order 13671 and to incorporate other technical and conforming changes. This regulatory amendment will take effect upon publication in the US Federal Register tomorrow (15 November 2018). See OFAC Notice.

US sanctions 6 as Specially Designated Global Terrorists

Logo_of_the_U.S._Office_of_Foreign_Assets_Control_(OFAC)OFAC has designated 4 Hizballah-affiliated individuals as Specially Designated Global Terrorists (SDGTs), pursuant to Executive Order 13224, for “lead[ing] and coordinat[ing] the group’s operational, intelligence, and financial activities in Iraq” (US asset freezes imposed). The 4 individuals – who are also subject to secondary sanctions under the Hizballah Financial Sanctions Regulations – are: Shibl Muhsin ‘Ubayd Al-Zaydi; Yusuf Hashim; Adnan Hussein Kawtharani; and Muhammad ‘Abd-Al-Hadi Farhat. These designations follow the signing into law (on 25 October 2018) of the Hizballah International Financing Prevention Amendments Act of 2018 (see previous blog). See OFAC Notice and US Treasury press release.

The US Department of State has also designated a Hizballah-linked individual, Jawad Nasrallah, and a Palestine and Egypt-based entity, Al-Mujahidin Brigades, as SDGTs under Executive Order 13224 (US asset freezes). See the unpublished Federal Register Notices here and here.

OFAC further extends EN+, RUSAL & GAZ Group licences

OFAC2OFAC has issued 4 general licences related to EN+ Group, RUSAL, and GAZ Group, which further extend the expiration date of their previous versions from 12 December 2018 to 7 January 2019. See General Licences 13G, 14C, 15B, and 16C. Links to OFAC Notice and US Treasury press release.

US grants Iraq 45-day sanctions waiver on Iranian energy

US-Iraq.jpgFollowing the full re-imposition of US Iran sanctions last week, the US has granted Iraq a temporary 45-day sanctions waiver to “continue purchasing natural gas and electricity from Iran”. See video announcement from the US Embassy in Baghdad, Iraq.

Eight other jurisdictions (China, India, Italy, Greece, Japan, South Korea, Taiwan and Turkey) were initially granted temporary waivers on the importation of Iranian oil, on the basis that they would stop or greatly reduce oil revenues in the coming weeks.

OFAC adds 12 to Russia/Ukraine sanctions lists

US Treasury Building2Yesterday, OFAC sanctioned 3 individuals and 9 entities in response to “Russia’s continuing malign activity and destabilizing behavior”. See OFAC Notice and US Treasury press release.

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.

OFAC releases 2017 Terrorist Assets Report

OFAC3OFAC has published its 2017 Terrorist Assets Report outlining the “nature and extent of assets held in the United States by terrorism-supporting countries and organizations engaged in international terrorism”.

The Report states that sanctions targeting international terrorist organisations had resulted in the blocking of approximately $44 million in the US in 2017 ($34 million in 2016). Whereas, approximately $202 million in assets relating to the four designated state sponsors of terrorism in 2017 (Iran, Sudan, Syria and North Korea) had been blocked ($149 million in 2016).

US sanctions on Iran back in force today; over 700 added to SDN list

Trump5Today, the US will complete the full re-imposition of sanctions on Iran that were lifted or waived under the JCPOA, aimed at “depriving the regime of the revenues that it uses to spread death and destruction around the world”, in particular oil revenue. The timing is said to coincide with the anniversary of the 1979 storming by Iranian revolutionaries of the US embassy in Tehran when 52 American diplomats were held hostage for 444 days. Key points:

  • The last set of Iran sanctions that were lifted under the JCPOA will be re-instated today, including measures against Iran’s energy, ship building, shipping, and banking sectors (the first set of measures were imposed on 7 August 2018).
  • Over 700 individuals, entities, vessels and aircraft have also been added to the SDN list, including 50 Iranian banks and their foreign and domestic subsidiaries, oil exporters, and shipping companies – see OFAC Notice, Treasury press release, and new OFAC FAQs.
  • 8 jurisdictions (China, India, Italy, Greece, Japan, South Korea, Taiwan and Turkey) will be granted temporary waivers on the importation of Iranian oil, on the basis that they will stop or greatly reduce oil revenues in the coming weeks.
  • An amendment to the Iranian Transactions Sanctions Regulations will take effect today, reflecting the re-imposition of sanctions pursuant to certain sections of Executive Order 13846. See White House Factsheet.

A Joint Statement from EU High Representative Federica Mogherini, France, Germany, and the UK says that they “deeply regret the further re-imposition of sanctions by the US” and have committed to work on the “preservation and maintenance of effective financial channels with Iran, and the continuation of Iran’s export of oil and gas”. The EU Special Purpose Vehicle (SPV), whose aim is to safeguard non-US trade with Iran, is not yet in place (see previous blog). In a Special Press Briefing last week, US Treasury Secretary Steven Mnuchin said that “if there are transactions that go through [the SPV which] have the intent of evading [US-Iran] sanctions, we will aggressively pursue our remedies”. Link to Updated UK Guidance on Trade and Export with Iran.