INTERNATIONAL SANCTIONS DECEMBER 2023

2024-01-04 International Sanctions Newsletters

I. EUROPEAN UNION

HUMAN RIGHTS

On 4 December 2023, Council Decision (CFSP) 2023/2721 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.

In accordance with Article 14(4) of Regulation (EU) 2020/1998, the Council has reviewed the list of natural and legal persons, entities and bodies subject to restrictive measures contained in Annex I to that Regulation. It follows from that review that the entries for nine natural persons and three entities should be updated.

COUNTER-TERRORISM

On 7 December 2023, Council Decision (CFSP) 2023/2764 amending the list of persons, groups and entities subject to the provisions of Common Position 2001/931/CFSP on the application of specific measures to combat terrorism was published in the Official Journal of the European Union.

The Council has determined that decisions have been taken by a competent authority within the meaning of Article 1(4) of Common Position 2001/931/CFSP in respect of two persons who have been involved in terrorist acts within the meaning of Article 1(3) of that Common Position, and that the measures in Articles 2 and 3 of that Common Position should apply to those persons.

DEMOCRATIC REPUBLIC OF THE CONGO

On 11 December 2023, Council Decision (CFSP) 2023/2768 of 8 December 2023 amending Decision 2010/788/CFSP concerning restrictive measures in view of the situation in the Democratic Republic of the Congo was published in the Official Journal of the European Union.

An amendment is introduced concerning the extension of the restrictive measures until 12 December 2026, together with the introduction of a review clause related to the existing derogation mechanism.

On 21 December 2023, Council Implementing Decision (CFSP) 2023/2906 implementing Decision 2010/788/CFSP concerning restrictive measures in view of the situation in the Democratic Republic of the Congo was published in the Official Journal of the European Union.

This decision amends Annexes I and II to Decision 2010/788/CFSP by adding two natural persons to the list of sanctioned persons and removing two others.

MYANMAR/BURMA

On 11 December 2023, Council Decision (CFSP) 2023/2788 amending Decision 2013/184/CFSP concerning restrictive measures in view of the situation in Myanmar/Burma was published in the Official Journal of the European Union.

The EU remains deeply concerned about the continuing escalation of violence in Myanmar/Burma and the evolution towards a protracted conflict with consequences for the region. The Union condemns the continuing serious human rights violations by the Myanmar/Burma armed forces, including torture, sexual and gender-based violence, persecution of civil society members, human rights defenders and journalists, and attacks on the civilian population, in particular ethnic and religious minorities.

Given the lack of rapid progress in the situation in Myanmar/Burma, the Union has on several occasions expressed its readiness to take further restrictive measures against those responsible for undermining democracy and the rule of law and for the serious human rights violations taking place in that country.

In view of the continuing serious situation in Myanmar/Burma, four persons and two entities should be added to the list of natural and legal persons, entities and bodies set out in the Annex to Decision 2013/184/CFSP.

WAR IN UKRAINE

On 11 December 2023, Council Decision (CFSP) 2023/2792 amending Decision (CFSP) 2023/1532 concerning restrictive measures in view of Iran’s military support for Russia’s war of aggression against Ukraine was published in the Official Journal of the European Union.

An amendment has been made to Article 1 of Decision (CFSP) 2023/1532 by which six persons and five entities are included in the list of natural or legal persons, entities and bodies subject to restrictive measures set out in the Annex to the Decision.

On 18 December 2023, Council Decision (CFSP) 2023/2871 amending Decision 2014/145/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 amendment extends the restrictive measures and lays down provisions to prevent or detect cases of violation or circumvention of the prohibitions set out in the decision. In particular, the Council considers that sixty-one persons and eighty-six entities responsible for actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine should be added to the list of persons, entities and bodies subject to restrictive measures set out in the Annex to Decision 2014/145/CFSP.

On 18 December 2023, Council Decision (CFSP) 2023/2874 amending Decision 2014/512/CFSP concerning restrictive measures in view of actions by Russia which destabilise the situation in Ukraine was published in the Official Journal of the European Union.

An amendment is inserted which includes the introduction of a list of partner countries applying restrictive measures on imports of iron and steel, as well as import control measures substantially equivalent to those in Council Decision 2014/512/CFSP and Council Regulation (EU) No 833/2014. In addition, it extends certain clearance periods for imports of certain steel products.

In particular, the Council considers that it is appropriate to impose a prohibition on the import, purchase or transfer, directly or indirectly, of diamonds from Russia. That prohibition should apply to diamonds of Russian origin, to diamonds exported from Russia, to diamonds in transit through Russia and to Russian diamonds processed in third countries other than Russia. The ban applies to natural and non-industrial synthetic diamonds, as well as diamond jewellery, from 1 January 2024, and includes a phasing-in, from 1 March 2024 to 1 September 2024, of an indirect import ban on Russian diamonds when processed in third countries other than Russia, including jewellery incorporating diamonds originating in Russia. The phasing-in of indirect import bans takes into account the need to put in place an adequate traceability mechanism to allow for effective enforcement action and minimise disruption to market players.

MALI

On 11 December 2023, Council Decision (CFSP) 2023/2799 of 11 December 2023 amending Decision (CFSP) 2017/1775 concerning restrictive measures in view of the situation in Mali was published in the Official Journal of the European Union.

On the basis of a review of the restrictive measures referred to in Articles 1a(1) and 2a(1) and (2) of Decision (CFSP) 2017/1775, those measures should be extended until 14 December 2024, the grounds for the entries of two of the persons included in the lists of natural and legal persons, entities and bodies in Annex II to Decision (CFSP) 2017/1775 should be amended and one person should be removed from the list in that Annex.

SYRIA

On 19 December 2023, the Council Decision (CFSP) amending Decision 2013/255/CFSP concerning restrictive measures in view of the situation in Syria was published in the Official Journal of the European Union.

It includes an amendment extending the restrictive measures and establishing provisions to prevent or detect cases of violation or circumvention of the prohibitions set out in the decision. In conclusion, and in order to respond to the continuing urgency of the humanitarian crisis in Syria, which has been exacerbated by the earthquake, and with a view to facilitating the rapid delivery of assistance and providing predictability and legal certainty for certain defined categories of actors involved in humanitarian activities in Syria benefiting from the above exemption, it is appropriate to extend the exemption adopted in Decision (CFSP) 2023/408 until 1 June 2024, in line with the current end date for the application of Decision 2013/255/CFSP.

II. UNITED STATES

RUSSIA

As of 1 December 2023, OFAC has added 3 Russian companies and 3 Russian cargo ships to the sanctioned list.

The US Treasury Department’s Office of Foreign Assets Control (OFAC) imposed sanctions on three entities and identified as blocked assets three vessels that used Price Cap Coalition services while transporting Russian crude oil above the Coalition’s agreed maximum price. These sanctions build on previous Treasury actions in October and November of this year and again represent the Treasury’s commitment, along with its Coalition partners, to responsibly reduce the oil revenues that the Russian government uses to finance its war against Ukraine.

As of 5 December 2023, OFAC has added 11 Russian companies and 7 Russian individuals to the sanctioned list.

The US Treasury Department’s Office of Foreign Assets Control (OFAC) has designated 11 entities and seven individuals under Executive Order (E.O.) 14038 and one individual under E.O. 14024. This action increases pressure on the authoritarian regime of Alyaksandr Lukashenka (Lukashenka) for its brutal repression of Belarus’ democratic civil society, corrupt financial enrichment of the Lukashenka family and complicity in Russia’s unjustified war against Ukraine.

As of 12 December 2023, OFAC has added more than 100 entities and individuals related to sanctions evasion to the sanctioned list.

The US Treasury Department’s Office of Foreign Assets Control (OFAC) is following through on commitments made by G7 leaders by taking action against third country actors who materially support Russia’s war; acting against Russian military procurement networks and those who help Russia acquire key machines, tools, equipment and inputs; and further restricting Russia’s use of the international financial system to further its war in Ukraine.

The State Department is imposing sanctions on more than 100 entities and individuals, including those involved in sanctions evasion in numerous third countries, complicit in fostering Russia’s ability to wage its war against Ukraine, and responsible for bolstering Russia’s future energy production and export capacity.

As of 20 December 2023, OFAC has added a number of individuals and entities related to Russian crude oil to the sanctioned list.

The US Treasury Department’s Office of Foreign Assets Control (OFAC) has continued to strengthen enforcement of the Russian oil price cap, building on previous actions targeting ship and vessel owners involved in transporting Russian crude oil above the price cap. Consistent with previous actions taken by Price Cap Coalition partners, OFAC has designated a manager of vessels owned by the Russian government, as well as several little-known oil traders who have emerged as frequent participants in the maritime transport of Russian-origin oil following the imposition of the price cap.

IRAN

As of 7 December 2023, OFAC has added 10 entities and 4 individuals to the list of sanctioned persons.

The US Treasury Department’s Office of Foreign Assets Control (OFAC) has imposed sanctions on 10 entities and four individuals based in Iran, Malaysia, Hong Kong and Indonesia that support Iran’s production of unmanned aerial vehicles (UAVs). This network, led by Iran-based Hossein Hatefi Ardakani, has facilitated the procurement of hundreds of thousands of dollars worth of US- and foreign-origin components for the Islamic Revolutionary Guard Corps Aerospace Forces Self-Reliance Jihad Organisation (IRGC ASF SSJO) and its UAV programme.

TERRORISM

As of 7 December 2023, OFAC has added 7 entities and 6 individuals to the list of sanctioned persons.

The Treasury Department’s Office of Foreign Assets Control (OFAC) sanctioned 13 individuals and entities responsible for providing the Houthis in Yemen with tens of millions of dollars worth of foreign currency generated from the sale and shipment of Iranian commodities backed by the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF). Through a complex network of bureaux de change and businesses in multiple jurisdictions, these individuals, under the auspices of US-sanctioned Houthi and IRGC-QF financial facilitator Sa’id al-Jamal, serve as a major conduit through which Iranian money reaches the country’s militant partners in Yemen.

As of 13 December 2023, OFAC has added 7 persons to the list of sanctioned persons.

The US Treasury Department’s Office of Foreign Assets Control (OFAC) imposed a fourth round of sanctions on Hamas since the 7 October terrorist attack on Israel. Today’s action targets key officials who perpetuate Hamas’ violent agenda by representing the group’s interests abroad and managing its finances. OFAC coordinated closely with the UK to simultaneously designate several key Hamas officials.

As of 14 December 2023, OFAC has added 3 individuals and 1 Mexican entity to the list of sanctioned persons.

The Treasury’s Office of Foreign Assets Control (OFAC) sanctioned the transnational criminal organisation (TCO) Malas Mañas, a human smuggling and drug trafficking organisation based in Sonora, Mexico, along with two individuals from its support network,

As of 28 December 2023, OFAC has added 1 person and 3 entities to the list of sanctioned persons.

The Treasury Department’s Office of Foreign Assets Control (OFAC) designated one individual and three entities responsible for facilitating the flow of Iranian financial assistance to Houthi forces and their destabilising activities. The individuals designated today include the head of the Sana’a Foreign Exchange Association and three foreign exchange bureaus in Yemen and Turkey. These individuals have facilitated the transfer of millions of dollars to the Houthis under the direction of US-designated Sa’id al-Jamal, who is affiliated with Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF).

SUDAN

As of 4 December 2023, OFAC has added 3 persons and 1 entity to the list of sanctioned persons.

The US Treasury Department’s Office of Foreign Assets Control (OFAC) has designated several individuals for their role in undermining peace, security and stability in Sudan. These designations support the international community’s diplomatic efforts to end the conflict and demonstrate the United States’ commitment to achieving civilian rule and a transition to democracy.

NARCOTICS

As of 28 December 2023, OFAC has added 15 individuals and 2 entities to the list of sanctioned persons.

The US Treasury Department’s Office of Foreign Assets Control (OFAC) has sanctioned 15 Mexican individuals – several of whom are US fugitives – and two Mexican-based companies linked, directly or indirectly, to the Beltrán Leyva Organisation (BLO). The BLO remains one of the most powerful drug trafficking organisations in the world and is heavily involved in the transportation and distribution of deadly drugs, including fentanyl, to the United States. It has been a major supplier of cocaine to the US market for more than two decades.

HUMAN RIGHTS

As of 8 December 2023, OFAC has added 22 individuals to the list of those sanctioned for human rights violations.

CORRUPTION

On 1 December 2023, OFAC has added Luis Miguel Martínez Morales to the list of sanctioned persons.

The Treasury Department’s Office of Foreign Assets Control (OFAC) sanctioned Luis Miguel Martínez Morales for his role in corruption in Guatemala, where he participated in bribery schemes, including schemes involving government contracts. Martinez’s designation comes under Executive Order 13818, which implements and enforces the Magnitsky Human Rights Accountability Act and prosecutes perpetrators of serious human rights abuses and corruption around the world.

As of 11 December 2023, OFAC has added 2 natural persons and 44 entities to the list of sanctioned persons.

The US Treasury Department’s Office of Foreign Assets Control (OFAC) sanctioned two former Afghan government officials – Mir Rahman Rahmani (M. Rahmani) and his son, Ajmal Rahmani (A. Rahmani), collectively known as “the Rahmanis” – for their extensive role in transnational corruption, as well as 44 associated entities. These individuals and entities have been designated under Executive Order (E.O.) 13818, which implements and enforces the Magnitsky Human Rights Accountability Act and prosecutes perpetrators of serious human rights abuses and corruption around the world. Through their Afghan companies, the Rahmanis perpetrated a complex procurement corruption scheme that resulted in the misappropriation of millions of dollars from US government-funded contracts supporting Afghan security forces.

III. UNITED KINGDOM

HUMAN RIGHTS

As of 7 December 2023, OFSI has sanctioned 10 individuals AND 7 entities.

OFSI has sanctioned 10 individuals and 7 entities These sanctions include asset freezes and travel bans to deter those who have been involved in human rights violations. The regulations allow the government to impose financial sanctions, including asset freezes and travel bans, on persons, entities or bodies responsible for or involved in serious human rights violations. Sanctions target individuals and entities involved in activities such as human trafficking in Laos and Myanmar, as well as officials linked to repressive regimes in Belarus, Haiti, Iran and Syria.

COUNTER-TERRORISM

As of 11 December 2023, OFSI has sanctioned 1 individual.

OFSI has sanctioned 1 individual on the basis that he is a person involved within the meaning of the Anti-Terrorism (International Sanctions) (EU Exit) Regulations 2019 on the following ground: KHAIR has been involved in providing financial services, or making funds or economic resources available, for terrorist purposes, specifically to Hamas.

As of 13 December 2023, OFSI has sanctioned 7 individuals.

OFSI has sanctioned 7 individuals on the basis that they are members of or associated with Palestinian Islamic Jihad, an entity which is and/or has been involved in terrorist activities; have provided financial services or funds or economic resources for terrorist purposes, specifically to Hamas; are or have been associated with Hamas, an entity which is and/or has been involved in terrorist activities; are and/or have been responsible for the commission, preparation or instigation of, or have participated in or provided support for, acts of terrorism, including the promotion of hostage-taking on behalf of Hamas.

RUSSIA

As of 7 December 2023, OFSI has sanctioned 2 individuals.

The OFSI has sanctioned 2 individuals on the basis that they are part of the Callisto Group (aka Seaborgium, Star Blizzard, Cold River), are or have been involved in relevant cyber activities, such as being responsible for, participating in, supporting or promoting the commission, planning or preparation of relevant cyber activities. The Callisto Group, a cyber programme operated by Russian FSB officers, was responsible for intrusions into the Institute for Statecraft (IS), a UK-based think tank responsible for a programme to research, publicise and counter the threat posed to European democracies by disinformation and other forms of hybrid warfare. The hack and subsequent leak revealed official documents belonging to IS, the result of the preparation of spear-phishing campaigns and associated activities.

As of 11 December 2023, OFSI has added 1 administrative amendment to the sanctions regime against Russia.
As of 15 December 2023, OFSI has added a new designation and 27 variations to the sanctions regime against Russia have been introduced.
As of 18 December 2023, OFSI has added 1 administrative amendment and 1 amendment under the Russia sanctions regime.
As of 21 December 2023, OFSI has made a variation under the sanctions regime against Russia.

HAITI

As of 8 December 2023, OFSI has sanctioned 10 individuals AND 7 entities.

These sanctions included asset freezes and travel bans as part of a package of sanctions coordinated with the US and Canada. The sanctions targeted individuals involved in activities such as human trafficking in Haiti, among other human rights violations.

As of 11 December 2023, OFSI has added 4 new designations to the Haiti sanctions regime.

IRAN

As of 14 December 2023, OFSI has sanctioned 8 individuals and transferred 173 persons to the sanctions regime.

Transferred 173 designees from Iran’s human rights regime to the Iran sanctions regime and added 8 new designations to the Iran sanctions regime.

As of 18 December 2023, OFSI has made 3 administrative amendments under the Iran sanctions regime.
As of 21 December 2023, OFSI has made 36 administrative amendments under the Iran sanctions regime.

BELARUS

As of 6 December 2023, OFSI has sanctioned 1 entity.

OFSI has sanctioned 1 entity on the basis that it is or has been involved in obtaining a benefit from or supporting the Government of Belarus by conducting business in a sector of strategic importance to the Government of Belarus, namely the Belarusian defence and information, communications and digital technology sectors.

As of 7 December 2023, OFSI has sanctioned 17 individuals.

OFSI has sanctioned 17 individuals on the basis that they are implicated persons under the Belarus (Sanctions) (EU Exit) Regulations 2019 in relation to the following grounds: they are or have been responsible for, engaged in, provided support for, or promoted the repression of civil society or democratic opposition in Belarus and actions, policies or activities that undermine democracy or the rule of law in Belarus.