International sanctions have become a popular foreign policy instrument. Once limited to a few cases, they now have a broad mandate. In principle, sanctions aimed at addressing serious human rights violations, stopping 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. EUROPEAN UNION
RUSSIA
- On 4 February 2023, Council DECISION (CFSP) 2023/252 of 4 February 2023 amending DECISION 2014/512/CFSP concerning restrictive measures in view of actions by Russia destabilising the situation in Ukraine was published in the Official Journal of the European Union.
This amendment establishes two new maximum prices for authorised petroleum products, for petroleum products traded at a discount to the crude price and for petroleum products traded at a premium to the crude price. It also includes a transitional period of fifty-five days for vessels carrying petroleum products purchased and loaded in Russia by vessel before 5 February 2023 and unloaded before 1 April 2023.
- On 6 February 2023, Council DECISION (CFSP) 2023/261 of 6 February 2023 amending DECISION 2014/145/CFSP concerning restrictive measures in respect of actions which undermine or threaten the territorial integrity, sovereignty and independence of Ukraine was published in the Official Journal of the European Union. DMITRY Vladimirovich OVSYANNIKOV is removed from the list in Annex I.
- On 20 February 2023, Council DECISION (CFSP) 2022/388 of 20 February 2023 amending Decision (CFSP) 2022/266 concerning restrictive measures in response to the illegal recognition, occupation or annexation by the Russian Federation of certain areas of Ukraine not under its control was published in the Official Journal of the European Union. This Decision amends Article 1 by extending the effects of Decision 2022/266 until 24 February 2024.
- On 25 February 2023, Council Decision (CFSP) 2023/432 of 25 February 2023 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine has been published in the Official Journal of the European Union, where the following measures are taken:
- Eighty-seven (87) persons and thirty-four (34) entities are added to the list of sanctioned persons.
- Three banks are added to the list of exemptions from asset freezing.
- On 25 February 2023, Council Decision (CFSP) 2023/434 of 25 February 2023 amending Decision 2014/512/CFSP concerning restrictive measures in view of actions by Russia destabilising the situation in Ukraine was published in the Official Journal of the European Union. Where the following measures are taken:
- Prohibition to hold any position in ”European Critical Infrastructures” as described in Directives (EU) 2022/2557 and 2008/114/EC.
- A ban on the supply of gas storage capacity in the Union to Russian nationals, residents of Russia or legal persons established in Russia.
- To add 96 legal persons to Annex IV to Decision 2014/512/CFSP.
- Extend the suspension of radio fusion licences to Russian media.
SYRIA
- On 23 February 2023, Council DECISION (CFSP) 2023/408 of 23 February 2023 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.
In view of the severe humanitarian crisis in Syria, the EU decided that the Regulation should be amended to introduce an exemption for funds frozen from sanctioned persons when made available to organisations for humanitarian purposes, where no prior national authorisation is required.
DAESH
- On 3 February 2023, Commission Implementing Regulation (EU) 2023/249 of 3 February 2023 amending for the 333rd time Council Regulation (EC) No 881/2002 has been published in the Official Journal of the European Union, imposing certain specific restrictive measures directed against certain persons and entities associated with the ISIL (Da’esh) and Al-Qaida organisations, by including ”Islamic State of Iraq and the Levant in Southeast Asia” on the list of sanctioned persons in Annex I.
- On 10 February 2023, Commission Implementing Regulation (EU) 2023/329 of 10 February 2023 amending for the 334th 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, amending the identification data of twenty-six (26) natural persons and three (3) entities was published in the Official Journal of the European Union.
IRAN
- On 20 February 2023, Council DECISION (CFSP) 2023/381 of 20 February 2023 amending 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. Thirty-one (31) natural persons and two (2) entities are included.
MYANMAR/BURMA
- On 20 February 2023, Council Implementing Decision (CFSP) 2023/380 of 20 February 2023 amending Council 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. Nine (9) natural persons and seven (7) entities are added.
MALI
- On 25 February 2023, Council Decision (CFSP) 2023/431 of 25 February 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. One (1) natural person and one (1) entity are added to the lists of sanctioned persons.
BELARUS
- On 24 February 2023, Council Decision (CFSP) 2023/421 of 24 February 2023 amending Decision 2012/642/CFSP concerning restrictive measures in view of the situation in Belarus and Belarus’ involvement in the Russian aggression against Ukraine was published in the Official Journal of the European Union. 21 entries in Annex I Table A and 14 entries in Table B are replaced.
TERRORISM
- On 24 February 2023, Council Decision (CFSP) 2023/422 of 24 February 2023 updating the list of persons, groups and entities to which Articles 2, 3 and 4 of Common Position 2001/931/CFSP on the application of specific measures to combat terrorism apply, and repealing Decision (CFSP) 2022/1241, was published in the Official Journal of the European Union. The persons in the Annex are updated with thirteen (13) natural persons and twenty-one (21) entities in total.
2.UNITED STATES
RUSSIA
- On 1 2023, pursuant to Executive Order (E.O.) 14024, which authorises the imposition of sanctions against Russia for its harmful foreign activities, including the violation of basic principles of international law such as respect for the territorial integrity of other states, ten (10) individuals and twelve (12) entities have been added to the SDN list.
- On 24 February 2023, ninety-six (96), one hundred and twenty-two (122) entities and twenty-two (22) vessels were placed on the sanctioned list in relation to the situation in Ukraine by virtue of (EO-14024). Three (3) entities were removed from the lists.
The US Treasury Department’s Office of Foreign Assets Control (OFAC) is taking drastic measures to reduce Russia’s capacity in the unfolding armed conflict in Ukraine.
In one of its most significant sanctions actions to date, the US Treasury announces a new set of sanctions targeting the metals and mining sector of the Russian Federation’s economy under Executive Order 14024 and also imposes sanctions on a large number of Russian individuals and entities. Today’s action, along with additional measures taken by the State Department, the Commerce Department and the Office of the US Trade Representative, in coordination with G7 allies and partners, further isolates Russia from the international economy.
IRAN
- On 3 June 2022, pursuant to (E.O) 13382 ”Blocking the ownership of weapons of mass destruction and their supporters”, Paravars Pars (1) as an entity and seven (7) natural persons who served as directors of that company were included in the list of sanctioned persons.
The US Treasury Department’s Office of Foreign Assets Control (OFAC) today designated eight senior executives of Paravar Pars Company (Paravar Pars), an Iran-based company previously sanctioned by the United States and the European Union for manufacturing Shahed series unmanned aerial vehicles (UAVs) for Iran’s Islamic Revolutionary Guard Corps Aerospace Force (IRGC ASF). OFAC is also identifying two Islamic Republic of Iran Navy (IRIN) vessels, the IRIS MAKRAN and the frigate IRIS DENA, as property in which the Government of Iran has an interest.
“Iranian entities continue to produce UAVs for the IRGC and Iran’s military. More broadly, Iran is supplying UAVs for Russian combat operations aimed at attacking critical infrastructure in Ukraine,” said Treasury Under Secretary for Terrorism and Financial Intelligence Brian E. Nelson. “The United States will continue to aggressively target all elements of Iran’s UAV programme.”
Paravar Pars has manufactured and tested UAVs for the IRGC Air Force and the IRGC Navy, and the company played a specific role in the research, development and production of the Shahed-171 UAV.
- On 9 September 2023 and pursuant to IRAN-EO13846, nine (9) Iranian legal persons engaged in the production, refining and export of petroleum and petroleum products currently located in Malaysia and Singapore were added to the sanctioned list.
AGAINST DRUG TRAFFICKING
- On 22 February 2023 and by virtue of the (ILLICIT-DRGUS-EO14059) six (6) natural persons and six (6) entities were included in the list of sanctioned persons.
3. UNITED KINGDOM
AL-QAEDA
- On 8 February 2023 the UK Government, under the Regime: ISIL (Da’esh) and Al Qaida Sanctions Regime has made 29 administrative changes to the UK Sanction list (“UKSL List”).
RUSSIA
- On 8 February 2023 the UK Government, under the Regime: Russia (Sanctions) (Eu Exit) Regulations 2019, added fifteen (15) new individuals to the UK Sanctions List (“UKSL List”).
- On 24 February 2023 the UK Government, under the Regime: Russia (Sanctions) (Eu Exit) Regulations 2019, added ninety-two (92) new individuals to the UK Sanctions List (“UKSL List”).
CYBERSECURITY
- On 9 February 2023 the UK Government under the CYBER (sanctions) (EU exit) Regulations 2020 added 7 new designations to the UK Sanctions List (”UKSL List”) to the cyber sanctions regime.
GLOBAL ANTI-CORRUPTION
- On 10 February 2023 the UK Government under the Global Anti-Corruption Sanctions Regulations 2021 added 3 new designations to the UK Sanctions List (”UKSL List”) to the corruption sanctions regime.
IRAN
- On 20 February 2022 the UK Government, under the Regime: (Sanctions) (Human Rights) (EU Exit) Regulations 2019 to provide for the freezing of funds and economic resources of certain persons, entities or bodies implicated in the commission of serious human rights violations or abuses in Iran, has added eight (8) individuals to the UK Sanctions List (“UKSL List”).
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In Madrid, 28 February 2023
International Trade and Sanctions Department
