US continues Zimbabwe sanctions for 1 year

Zimbabwe.jpgThe US has decided to continue for 1 year its sanctions with respect to Zimbabwe by extending the national emergency as declared in Executive Order (EO) 13288. As a result, the individuals listed under EO 13288 (as amended by EO 13391 and EO 13469) will continue to be subject to asset freezes beyond 6 March 2018 for a further year. Publication in the US Federal Register here.

EU renews Zimbabwe sanctions until 20 Feb. 2019

EU2The EU has extended its sanctions on Zimbabwe until 20 February 2019, see Council Decision (CFSP) 2018/224. This decision to keep sanctions in place was taken so that the situation in Zimbabwe (given the change in leadership in December 2017) could become clearer.

As a result, EU travel restrictions and asset freezes will continue to be imposed on 7 people (Robert Mugabe, Grace Mugabe, Happyton Bonyongwe, Augustine Chihuri, Constantine Chiwenga, Perence Shiri and Phillip Sibando) and 1 entity (Zimbabwe Defence Industries). However, those sanctions are currently suspended, except in relation to Robert Mugabe, Grace Mugabe and Zimbabwe Defence Industries. The EU Notice explains that they may submit a request to the EU Council to seek a reconsideration of their respective listings before 1 November 2018, and may challenge the Council’s decision to renew in the EU General Court.

The EU has also taken the opportunity to update Robert Mugabe’s listing so that it now states “Former President”, see Commission Implementing Regulation (EU) 2018/223. UK OFSI Notice here.

EU to continue sanctions on Zimbabwe’s Robert Mugabe

Robert-Mugabe.jpgThe EU has announced that it is considering maintaining sanctions against Zimbabwe’s former President, Robert Gabriel Mugabe, on the basis of a new statement of reasons. The EU Notice explains (inter alia) that he may submit a request to the EU Council to obtain the intended statement of reasons for his designation by 29 January 2018. Mr Mugabe is currently listed in Annex I to Council Decision 2011/101/CFSP and Annex III to Council Regulation (EC) No 314/2004 (also on the US SDN list, see entry here).

See previous blog here on the existing US sanctions against Zimbabwe’s current President, Emmerson Mnangagwa.

Zimbabwe’s new President and US / EU sanctions

Emmerson MnangagwaAfter the 37-year rule of Robert Mugabe, Zimbabwe has sworn in Emmerson Mnangagwa as its new President. He is still subject to US sanctions for “undermining democratic processes or institutions in Zimbabwe” (SDN entry here, and OFAC Notice here).

EU sanctions on Mr Mnangagwa (imposed on him for being a member of the Zimbabwean government) were lifted on 20 February 2016, see: Commission Implementing Regulation (EU) 2016/218, amending Council Regulation (EC) 314/2004. Maya Lester QC, instructed by Peters & Peters Solicitors, acted in a legal challenge in the EU court in which Mr Mnangagwa & others challenged their inclusion in the EU measures.

USA – Zimbabwe de-listing & CAR designations


OFAC has removed Zimbabwe’s former Minister of Water Resources Munacho Mutezo from its SDN List. Mr Mutezo’s removal follows his expulsion from the ZANU-PF party for supporting Joice Mujuru, former Vice-President who was expelled following accusations that he tried to depose President Mugabe. The circumstances of Mr Mutezo’s de-listing are similar those of Sylvester Nguni in November 2016, another former ZANU-PF member who, like Mr Mutezo, joined the opposition party Zimbabwe People First after his explusion from ZANU-PF (see previous blog).

Central African Republic

OFAC has designated Abdoulaya Hissene and Maxime Mokom under its CAR sanctions for engaging in actions that threaten the peace, security, or stability of the CAR. They are both said to have been involved in failed coup attempts, preventing people from voting, and lethal violence involving civilians and security forces.

EU renews Zimbabwe listings and adds exception to arms embargo

zimbabwe-victoria-falls-1The EU has renewed the listings of the 7 people and 1 entity targeted by its Zimbabwe sanctions for a further year, until 20 February 2018.  Currently the sanctions are suspended in respect of all listed people and entities except for Robert Mugabe, Grace Mugabe, and Zimbabwe Defence Industries. See Council Decision 2017/288 amending Council Decision 2011/101/CFSP and the EU’s notices here and here.

It has also introduced an exception to its arms embargo on Zimbabwe, allowing for the export of certain explosive substances where they are solely for use in Zimbabwe’s civilian mining and infrastructure projects. See Council Regulation 2017/284 amending Council Regulation 314/2004 and Council Decision 2017/288 amending Council Decision 2011/101/CFSP.

OFAC Zimbabwe & narcotics de-listings


OFAC has de-listed Slyvester Nguni, previously a member of President Robert Mugabe’s ZANU-PF political party and former minister who now belongs to opposition party Zimbabwe People First.  He was expelled from ZANU-PF for allegedly supporting Joice Mujuru, another ex-party member who was expelled following accusations that he tried to depose President Mugabe.


OFAC has de-listed 9 people and 3 entities who were designated as SDNs under its anti-narcotics sanctions, and amended the entries for 2 others.

The details are here.

US de-lists several people and entities from Zimbabwe sanctions

OFAC has removed several people and entities from its SDN List, where they were listed under US sanctions on Zimbabwe.  Those de-listed include deceased members of Robert Mugabe’s Zanu PF political party, divorced spouses of party officials, and a variety of companies.  Robert Mugabe and his wife Grace remain subject to sanctions, as they do in the EU where sanctions now apply only to them and the arms manufacturer Zimbabwe Defence Industries (see previous blog).

The full details of the changes are here.