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 are the overuse of sanctions and their increasing use as an instrument of power. They have become a key element in the geopolitics of the international chessboard. 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 they affect not only the sanctioned countries and individuals, but also those who trade with them in some way.
I. EUROPEAN UNION
- On 24 April 2023, Council Implementing Decision (CFSP) 2023/854 of 20 March 2023 amending Decision 2010/413/CFSP concerning restrictive measures against Iran was published in the Official Journal of the European Union.
The Council decided to sanction the entity Fajr Aviation Composite Industries, a subsidiary of IAOI within MODAFL, both already designated by the EU, for producing mainly composite materials for the aviation industry. This subsidiary in particular manufactures drones, which it allegedly uses to destabilise the region.
- On 24 April 2023, Council Implementing Decision (CFSP) 2023/849 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.
With regard to Iran, the Union considers the human rights situation in that state to be particularly “alarming”, and the Council has therefore included eight persons and one entity on the list of natural and legal persons, entities and bodies subject to restrictive measures.
These individuals have been designated for allegedly being responsible for serious human rights violations in Iran, targeting women or demonstrators in protests. The entity listed this time is an Iranian mobile service provider that has been at the forefront of the deployment of the Iranian government’s planned global telecommunications surveillance architecture to silence critical and dissenting voices in Iran. He has also obtained information that has subsequently been used by the government to curb protests.
- On 24 April 2023, Council Implementing Decision (CFSP) 2023/854 of 24 April 2023 implementing Decision 2013/255/CFSP concerning restrictive measures in view of the situation in Syria was published in the Official Journal of the European Union.
In view of the gravity of the situation, the Council considers that twenty-five individuals and eight entities should be placed on the list of natural and legal persons, entities or bodies subject to restrictive measures. Fifteen individuals have been listed for profiting from the war economy, in particular for trafficking in the synthetic drug captagon. This business model is organised by the regime, which profits from this activity. The other individuals have also been sanctioned for supporting the regime, through financial support and fuel smuggling. In addition, the designated entities are related militias and groups involved in smuggling other drugs and phosphate mines.
DAESH, AL-QAIDA AND PERSONS, GROUPS, UNDERTAKINGS AND ENTITIES ASSOCIATED WITH THEM
- On 24 April 2023, Council DECISION (CFSP) 2023/848 of 24 April 2023 amending Decision (CFSP) 2016/1693 concerning restrictive measures against ISIL (Da’esh) and Al-Qaida and individuals, groups, undertakings and entities associated with them was published in the Official Journal of the European Union.
The Council, in view of the continuing threat posed by ISIL (Da’esh) and Al-Qaeda and by individuals, groups, undertakings and entities associated with them, has decided to add two individuals and one group to the list of persons.
II. UNITED STATES
- On 19 April 2023, by virtue of Executive Order (E.O.) 13382, one individual and six entities have been sanctioned.
The US Treasury Department’s Office of Foreign Assets Control (OFAC) designated an individual and six entities in a sanctions evasion network that has facilitated Iran’s procurement of electronic components for its destabilising military programmes, including those used in unmanned aerial vehicles (UAVs). In particular, this action targets the US-designated head of Iran’s Pardazan System Namad Arman (PASNA) and the entity’s front companies and suppliers based in Iran, Malaysia, Hong Kong and the People’s Republic of China that have enabled PASNA’s procurement of goods and technology. This action also updates PASNA’s entry on OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List) to include an alias and the names of two shell companies used by PASNA in its procurement activities.
- On 24 April 2023, the Treasury Department’s Office of Foreign Assets Control (OFAC) sanctioned three officers of the Iranian Security Forces (LEF) and the Islamic Revolutionary Guard Corps (IRGC) and the Secretary of the Supreme Council for Cyberspace, pursuant to Executive Order (E.O.) 13687.
The Treasury Department’s Office of Foreign Assets Control (OFAC) sanctioned four senior officials of Iran’s Law Enforcement Forces (LEF) and the Islamic Revolutionary Guard Corps (IRGC), the main Iranian security forces responsible for the regime’s brutal crackdown on protests. OFAC is also taking action against the new Secretary of Iran’s Supreme Council for Cyberspace (CSC), the authority responsible for Iran’s cyberspace policy and the blocking of popular websites. Today’s measures are being taken in coordination with the UK, which is also imposing similar sanctions on senior Iranian security officials.
- On 12 April 2023, by virtue of Executive Order (E.O.) 14024, 25 individuals and 29 entities connected to 20 jurisdictions have been designated.
The US Treasury Department’s Office of Foreign Assets Control (OFAC) is further restricting Russia’s access to the international financial system through facilitators and their companies. The US, in coordination with the UK, is targeting the facilitation network of Alisher Usmanov, who is subject to sanctions in multiple jurisdictions. This action seeks to reinforce existing measures and further disrupt Russia’s importation of critical technologies used in its war against Ukraine.
The US State Department is simultaneously designating several entities operating in the defence sector of the Russian Federation’s economy and entities supporting Russia’s war against Ukraine, as well as additional entities associated with the Russian State Atomic Energy Corporation (Rosatom).
- On 3 April 2023, by virtue of Executive Order (E.O.) Executive Order 13441, two individuals have been designated.
The US Treasury Department’s Office of Foreign Assets Control (OFAC) designated two Lebanese brothers – Raymond Zina Rahme and Teddy Zina Rahme – as having used their wealth, power and influence to engage in corrupt practices that contribute to the breakdown of the rule of law in Lebanon, thereby undermining Lebanese democratic processes.
“The action underscores the United States’ commitment to shine a light on corrupt actions, which continue to unfairly affect the Lebanese people,” said Brian E. Nelson, Under Secretary of the Treasury for Terrorism and Financial Intelligence. “Now more than ever, the Lebanese government must implement the economic and political reforms it desperately needs,” he added.
- As of 14 April 2023, by virtue of Executive Order (E.O) 14059, eight companies have been designated.
The US Treasury Department’s Office of Foreign Assets Control (OFAC) has designated two entities in the People’s Republic of China (PRC) and five individuals, based in the PRC and Guatemala, for supplying precursor chemicals to drug cartels in Mexico for the production of illicit fentanyl destined for US markets.
“Illicit fentanyl is responsible for the deaths of tens of thousands of Americans each year,” said Treasury Under Secretary for Terrorism and Financial Intelligence Brian E. Nelson. “Treasury, as part of the government-wide effort to respond to this crisis, will continue to vigorously apply our tools to prevent the transfer of precursor chemicals and machinery needed to produce this drug.”
This action was carried out in partnership and close coordination with the Drug Enforcement Administration and the Department of Justice.
- On 18 April 2023, OFAC, pursuant to Executive Order (E.O.) , 13224, sanctioned 52 individuals and entities for membership in an international money laundering and sanctions evasion network.
The entities and individuals are from Lebanon, the United Arab Emirates, South Africa, Angola, Côte d’Ivoire, the Democratic Republic of Congo, Belgium, the United Arab Emirates, the United Kingdom, and Hong Kong. This network facilitated the payment, shipment, and delivery of cash, diamonds, precious gems, art, and luxury goods for the benefit of Hezbollah financier and Global Terrorist Nazem Said Ahmad, who was designated on December 13, 2019, for providing material support to Hezbollah. This designation is part of a coordinated action with the Department of Homeland Security, the State Department’s Rewards for Justice programme, and the United Kingdom.
“The individuals involved in this network used shell companies and fraudulent schemes to disguise Nazem Said Ahmad’s role in financial transactions,” said Treasury Under Secretary for Terrorism and Financial Intelligence Brian E. Nelson.
III. UNITED KINGDOM
- On 12 April 2023 the UK Government, under the Regime: Russia (Sanctions) (Eu Exit) Regulations 2019, made 8 administrative amendments under the Russia sanctions regime to the UK Sanctions list.
- On 21 April 2023 the UK Government has, under the Regime: Russia (Sanctions) (Eu Exit) Regulations 2019, added 3 new designations under the Russia sanctions regime and 2 new designations under the global human rights sanctions regime to the UK Sanction list.
- On 24 April 2023 the UK Government, pursuant to The Iran (Sanctions) (Human rights) (EU EXIT) Regulations 2019 has added to the UK Sanction list (“UKSL List”) 4 new designations under the Iran (Human rights) sanctions regime.
In Madrid, 30 April 2023
Department of International Trade and Sanctions