International sanctions have become a popular foreign policy instrument. Once limited to a few cases, they are now widely used. Initially, sanctions aimed at addressing gross human rights violations, halting arms sales to parties to armed conflicts and supporting peace negotiations are an important political instrument. However, there is growing evidence that the practice of international sanctions has become more of a problem than a solution for a humane and peaceful international order. The main causes are the excessive use of sanctions in general and the increasing use of sanctions as an instrument of power. These developments have also increased the negative side effects of sanctions.
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 is international, this may be of concern to you, as they affect not only the sanctioned countries and individuals, but also those who do business with them.
1. UNITED STATES
As of 1 August 2022, Executive Order (E.O) 13846, authorising the imposition of sanctions against Iran for the ”international sanctions evasion network in support of Iran’s petrochemical sales” has added six (6) entities and one (1) vessel to the SDN list.
The US Treasury Department’s Office of Foreign Assets Control (OFAC) has taken action against companies used by Iran’s Persian Gulf Petrochemical Industry Commercial Co (PGPICC), one of Iran’s largest petrochemical brokers, to facilitate the sale of tens of millions of dollars in Iranian petroleum and petrochemical products from Iran to East Asia. PGPICC is a subsidiary of the Iranian petrochemical conglomerate Persian Gulf Petrochemical Industry Co. (PGPIC), which accounts for half of all Iran’s petrochemical exports.
As of 2 August 2022 under Executive Order (E.O) 14024 authorising the imposition of sanctions against Russia for ”intent to undermine the democracy and institutions of the United States and its allies” thirteen (13) individuals, thirty-five (35) entities, two (2) vessels and three (3) entities have been added.
The US Treasury Department’s Office of Foreign Assets Control (OFAC) has imposed a new round of sanctions against Kremlin-related elites, a major multinational corporation and sanctions evasion operation, and a yacht under Executive Order (EO) 14024. These elites and companies operate in economic sectors that generate significant revenues for the Russian regime, including from sources outside Russia.
As of 8 August 2022 under Executive Order (E.O) 13694 authorising the imposition of sanctions on various individuals and entities that pose a ”danger to cybersecurity”, by which one (1) entity has been added.
The US Treasury Department’s Office of Foreign Assets Control (OFAC) sanctioned virtual currency mixer Tornado Cash, which has been used to launder more than $7 billion in virtual currency since its inception in 2019. This includes more than $455m stolen by the Lazarus Group, a Democratic People’s Republic of Korea (DPRK) state-sponsored hacking group that was sanctioned by the US in 2019, in the largest virtual currency heist known to date.
As of 15 August 2022 and pursuant to Executive Order (E.O) 13818 authorising the imposition of sanctions on persons involved in serious human rights abuses and corruption, three (3) Global Magnitsky partners have been listed.
2. UNITED KINGDOM
As of 2 August 2022 the UK Government, under the Regime: Russia (Sanctions) (Eu Exit) Regulations 2019, has added two (2) natural persons to the UK Sanctions List (“UKSL List”).
On 24 August 2022 the UK Government, pursuant to the Regime: Myanmar (Sanctions) Regulations 2021: concerning restrictive measures in respect of actions which undermine or threaten the territorial integrity, sovereignty and independence of Ukraine has added three (3) entities to the UK Sanctions List (”UKSL List”).
3. EUROPEAN UNION
On 4 August 2022 the Council Implementing Regulation 2022/1354 of 4 August 2022 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions which undermine or threaten the territorial integrity, sovereignty and independence of Ukraine has been published in the Official Journal of the European Union taking the decision to add two (2) individuals to the Sanctions List.
In Madrid, 31 July 2022
International Trade and Sanctions Department
Lupicinio International Law Firm
Lupicinio International Law Firm
C/ Villanueva 29
P: +34 91 436 00 90