International sanctions have become a popular foreign policy instrument in an increasingly multipolarised world. Once limited to a few cases, they are now extremely widespread. There is growing evidence that international sanctions are a problem rather than a solution for achieving a peaceful international order. The main causes for this been their overuse and their increasing use as an instrument of power. They have become a key element in the geopolitics of the international chessboard. However, their abusive use has led to an increase in their negative side-effects.
We believe it is important to keep a register of legal and natural persons sanctioned by the United Kingdom, the European Union, and the United States of America. If your business has an international component, this may be of concern to you, as it affects not only the sanctioned countries and individuals, but also those who do business with them in some way
I. EUROPEAN UNION
IRAN
- On 26 June 2023, Council Implementing Decision (CFSP) 2023/1299 implementing Decision 2011/235/CFSP concerning restrictive measures directed against certain persons and entities in view of the situation in Iran was published in the Official Journal of the European Union.
RESTRICTIVE MEASURES AGAINST SERIOUS HUMAN RIGHTS VIOLATIONS AND ABUSES
- On 5 June 2023, Council Decision (CFSP) 2023/1099 amending Decision (CFSP) 2020/1999 concerning restrictive measures against serious violations and abuses of human rights was published in the Official Journal of the European Union.
Seven (7) natural persons are added to the list in Annex I to that Decision.
RUSSIA
- On 5 June 2023, Council Decision (CFSP) 2023/1094 of 5 June 2023 amending Decision 2014/154/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine was published in the Official Journal of the European Union. This decision amends Article 1(1)(e) and Article 2(1)(g).
- On 19 June 2023, Council Decision (CFSP) 2023/1188 amending Decision 2014/386/CFSP concerning restrictive measures in response to the illegal annexation of Crimea and Sevastopol was published in the Official Journal of the European Union.
This amendment extends the validity of this regulation until 23 June 2024.
- On 23 June 2023, the so-called eleventh package of sanctions in response to Russia’s invasion of Ukraine was published in the Official Journal of the European Union. This package targets the following[1] :
- Strengthen bilateral and multilateral cooperation with countries outside the Union to avoid circumvention of sanctions imposed;
- Ban transit of goods and technology through Russia
- Tighten export restrictions
If you are interested in more information on this new sanctions package, please click here.
ISIL (Daesh) and Al Qaida
- On 8 June 2023, Council Implementing Regulation (EU) 2023/1126 implementing Regulation (EU) 2016/1686 imposing additional restrictive measures against ISIL (Da’esh) and Al Qaeda and natural or legal persons, entities or bodies associated with them was published in the Official Journal of the European Union.
Entry 9 of Annex I to the Regulation concerning Sultan Aziz Azam is deleted.
- On 09 June 2023, Commission Implementing Regulation (EU) 2023/1140 amending for the 337th time Council Regulation (EC) No 881/2002 imposing certain specific restrictive measures directed against certain persons and entities associated with ISIL (Da’esh) and Al-Qaida organisations was published in the Official Journal of the European Union.
Under this Implementing Regulation the entries for two (2) natural persons in Annex I of Regulation (EC) 881/2002 are deleted.
SOMALIA
- On 12 June 2023, Council Implementing Decision (CFSP) 2023/1148 of 12 June 2023 implementing Decision 2010/231/CFSP concerning restrictive measures against Somalia was published in the Official Journal of the European Union.
This amendment includes one (1) natural person in Annex I to the Decision.
DEMOCRATIC REPUBLIC OF THE CONGO
- Council Implementing Regulation (EU)2023/1183 of 19 June 2023 implementing Regulation (EC) No 1183/2005 concerning restrictive measures in view of the situation in the Democratic Republic of Congo.
Entries 8 and 9 of Annex Ia Section A “Persons” to Regulation (EU) 1183/2005 are deleted.
II. UNITED STATES
IRAN
- On 2 June 2023, by virtue of Executive Order (E.O) 13846, two (2) individuals and two (2) legal persons have been added to the list of sanctioned persons.
The US Treasury Department’s Office of Foreign Assets Control (OFAC) is designating the Iran-based technology company known as “Arvan Cloud”, two senior Arvan Cloud employees, and an affiliated company based in the United Arab Emirates for their role in facilitating the Iranian regime’s censorship of the internet in Iran.
RUSSIA
- On 19 May 2023, by virtue of Executive Order (E.O.) 14024, seven (7) individuals and one (1) legal person have been included in the list of sanctioned persons.
The US Treasury Department’s Office of Foreign Assets Control (OFAC) designated seven prominent members of a group of individuals linked to Russian intelligence services for their role in the Russian Federation government’s intentions to influence Moldova. An entity owned or controlled by one of these individuals has also been designated.
- On 23 June 2023, by virtue of Executive Order (E.O.) 14024, two (2) natural persons were included in the list of sanctioned persons.
The US Treasury Department’s Office of Foreign Assets Control (OFAC) sanctioned two Democratic People’s Republic of Korea (DPRK) nationals involved in the procurement of equipment and materials that support the DPRK’s ballistic missile programme. The DPRK continues to use a network of proxies in foreign countries, including the People’s Republic of China (PRC) and Iran, to illicitly import restricted components necessary to conduct research and development for its WMD and ballistic missile programmes, in violation of multiple UN Security Council resolutions.
- On 27 June 2023, pursuant to Executive Order (E.O) 14024, one (1) natural person and four (4) entities were included in the list of sanctioned persons.
The Treasury Department’s Office of Foreign Assets Control (OFAC) sanctioned four companies and one individual linked to the violent Russian military group PMC Wagner (Wagner Group) and its founder and owner Yevgeniy Prigozhin, previously sanctioned by the United States, the European Union (EU), Canada and the United Kingdom (UK). The Wagner Group exploits insecurity around the world, committing atrocities and criminal acts that threaten the security, good governance, prosperity, and human rights of nations, as well as exploiting their natural resources. The entities targeted in the Central African Republic (CAR), the United Arab Emirates (UAE) and Russia have engaged in illicit gold transactions to fund the Wagner Group to sustain and expand its armed forces, including in Ukraine and Africa, while the targeted individual has been instrumental in the activities of Wagner Group units in Mali.
NON-PROLIFERATION OF WEAPONS, COUNTER-NARCOTICS
- On 06 June 2023, by virtue of Executive Order (E.O) ILLICIT-DRUGS-EO14059, ten (10) natural persons and seven (7) legal persons have been included in the list of sanctioned persons.
The Treasury Department’s Office of Foreign Assets Control (OFAC) designated two senior members of the Jalisco Cartel – New Generation (CJNG) for trafficking high-calibre firearms from the United States and fuel theft in Mexico. In addition, OFAC designated another individual and a Mexican entity as supporting the CJNG by laundering the proceeds of illicit drug trafficking. The CJNG is a violent Mexican-based drug trafficking organisation responsible for a significant portion of the trafficking of fentanyl and other lethal drugs into the United States.
COUNTER-TERRORISM
- On 08 June 2023, by virtue of Executive Order (O) 13224, as amended by (E.O) 13886, two (2) natural persons have been placed on the sanctions list.
- As of 20 June 2023, by virtue of Executive Order (O) 13224, as amended by (E.O) 13886, four (4) natural persons have been placed on the sanctions list.
NORTH KOREA
- As of 15 June 2023, pursuant to the North Korea Sanctions Regulations, two (2) natural persons have been placed on the sanctions lists.
The US Treasury Department’s Office of Foreign Assets Control (OFAC) sanctioned two Democratic People’s Republic of Korea (DPRK) nationals involved in the procurement of equipment and materials that support the DPRK’s ballistic missile programme. The DPRK continues to use a network of proxies in foreign countries, including the People’s Republic of China (PRC) and Iran, to illicitly import restricted components necessary to conduct research and development for its illegal weapons of mass destruction (WMD) and ballistic missile programmes, in violation of multiple UN Security Council resolutions.
BIRMANIA
- As of 21 June 2023, three (2) entities have been placed on the sanctions list by virtue of Executive Order (O) 14014.
III. UNITED KINGDOM
ISLAMIC STATE (DA’ESH) AND AL QAEDA
- On 6 June 2023 the British Government under the ISL (DA’ESH) and Al-Qaida sanctions regime revoked two individuals from the sanctioned lists.
DEMOCRATIC REPUBLIC OF THE CONGO
- On 19 June 2023, the UK Government under the DRC Sanctions Regime placed two individuals on the sanctions list and made two additional designations under the Syria Sanctions Regime.
RUSSIA
- On 23 June 2023 the UK Government, under the Regime: Russia (Sanctions) (Eu Exit) Regulations 2019, has added three (3) new designations under the Russia sanctions regime to the UK Sanctions list.
[1] Chronology – EU restrictive measures against Russia for its actions in Ukraine. Council of the European Union. Retrieved from: Chronology – EU restrictive measures against Russia for its actions in Ukraine – Consilium (europa.eu) on 27 June 2023.
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In Madrid, on June 30, 2023
International Trade and Sanctions Department
