International Sanctions February 2024

I. UNITED STATES

CISJORDAN

  • On 1 February 2024, pursuant to Executive Order (E.O) 14115, four individuals have been added to the OFAC Sanctions List.

The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) has designated four individuals as undermining peace, security, and stability in the West Bank; related to the West Bank.

IRAN

  • On 2 February 2024, pursuant to Executive Order (E.O) 13224 , four individuals have been added to the OFAC Sanctions List.

The Treasury Department’s Office of Foreign Assets Control (OFAC) sanctioned six officials of the Iranian Islamic Revolutionary Guard Corps Cyber Command (IRGC-CEC), an Iranian government organisation responsible for a series of malicious cyber activities against critical infrastructure in the United States and other countries.

TERRORISM

  • On 2 February 2024, pursuant to Executive Order (E.O) 13382, four entities have been added to OFAC’s sanctioned list.

The US Treasury Department’s Office of Foreign Assets Control sanctioned a key procurement network of prolific suppliers of sensitive materials and technology for Iran’s ballistic missile and unmanned aerial vehicle (UAV) programmes, including the Shahed series UAV produced by Iran’s Shahed Aviation Industries Research Center (SAIRC).

The four Iranian and Hong Kong-based entities designated have operated as covert procurement entities for OFAC, who are actively involved in supporting multiple Iranian military organisations, including the Islamic Revolutionary Guard Corps (IRGC). In addition, OFAC has designated a Hong Kong-based front company involved in the sale of hundreds of millions of dollars worth of Iranian goods for the benefit of the Islamic Revolutionary Guard Corps-Quds Force (IRGC-QF).

  • On 14 February 2024, pursuant to Executive Order (E.O) 13224, three individuals and four entities have been added to OFAC’s sanctioned list.

The Treasury Department’s Office of Foreign Assets Control (OFAC) sanctioned a procurement network responsible for facilitating the illegal export of goods and technology from more than two dozen US companies to end-users in Iran, including the Central Bank of Iran (CBI), which is designated for its role in providing financial support to the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) and Hezbollah.

These designations concern three individuals and four entities linked to the procurement of sophisticated US technology for use by the CBI, in violation of US export restrictions and sanctions. Among the goods and technology procured by the CBI were items classified as information security items subject to national security and anti-terrorism controls by the US Department of Commerce’s Bureau of Industry and Security.

  • Designation; Anti-Terrorism General License Issuance; Sanctions Compliance Guidance for the Provision of Humanitarian Assistance and Critical Commodities to the Yemeni People dated 16 February 2024.

The US Treasury Department’s Office of Foreign Assets Control (OFAC) is issuing an OFAC Enforcement Advisory: Guidance for the Provision of Humanitarian-Related Assistance and Critical Commodities to the Yemeni People in response to questions from the NGO community and the general public on how to ensure that humanitarian assistance and trade continue to flow to the Yemeni people while complying with OFAC sanctions.

OFAC is also issuing General Counterterrorism License 28, “Authorising Transactions for Third Country Diplomatic and Consular Missions Involving Ansarallah”.

  • On 16 February 2024, pursuant to Executive Order (E.O) 13886, one entity has been added to OFAC’s sanctioned list.
  • On 27February 2024, pursuant to Executive Order (E.O) 13224, one entity has been added to OFAC’s sanctions list.

The Treasury Department’s Office of Foreign Assets Control (OFAC) has sanctioned two companies registered in Hong Kong and the Marshall Islands that own and operate a vessel, the Panamanian-flagged KOHANA, which ships more than $100 million in Iranian commodities to companies in the People’s Republic of China (PRC) on behalf of the Ministry of Defence and Armed Forces Logistics of Iran (MODAFL). MODAFL continues to facilitate the delivery of Iranian weapons, particularly unmanned aerial vehicles (UAVs), to Russia in support of its war of aggression in Ukraine and to Iranian-aligned militias in the Middle East.

The Treasury Department’s Office of Foreign Assets Control (OFAC), in coordination with the United Kingdom, is taking action against the Deputy Commander of Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF), Mohammad Reza Falahzadeh, as well as a member of the Houthi group. OFAC has also designated the owner and operator of a vessel used to transport Iranian goods sold in support of both the Houthis and the IRGC-QF. Revenues generated through these illicit networks enable the Houthis to conduct their militant activities, including numerous terrorist attacks in the region using unmanned aerial vehicles and advanced missiles.

DRUG TRAFFIC:

  • On 28 February 2024, by virtue of Executive Order (E.O) 14059, three entities and 4 individuals have been added to the OFAC sanctioned list. In addition, 6 individuals have been removed from the same list..

ECUADOR

  • On 7 February 2024, by virtue of Executive Order (E.O) 14059, the “Los Choneros” gang and its leader have been sanctioned by OFAC.

The U.S. Treasury Department’s Office of Foreign Assets Control sanctioned one of Ecuador’s most violent gangs, “Los Choneros”, and its leader, José Adolfo Macías Villamar (also known by the alias “Fito”), under enforcement by counter-narcotics authorities. OFAC’s action follows a sharp increase in violence in Ecuador attributed to the actions of “Los Choneros” and other drug gangs in the country.

RUSSIA

  • On 8 February 2024, under Executive Order (E.O) 13382, four entities and one vessel have been subject to a second application of sanctions by OFAC.

The US Treasury Department’s Office of Foreign Assets Control (OFAC) takes its second price cap enforcement action of 2024, imposing sanctions on four entities and identifying one vessel as blocked property. The network of these entities and the vessel were involved in a price cap violation scheme in late 2023. OFAC is also issuing two new commitments implementing the G7 commitments to ban the import of Russian diamonds.

  • On 20 February 2024, pursuant to Executive Order (E.O) 13694, two individuals have been added to OFAC’s sanctioned list.

The United States has designated two individuals affiliated with the Russian-based LockBit ransomware group. This action is the first in an ongoing collaborative effort with the US Department of Justice, the Federal Bureau of Investigation and its international partners against LockBit.

NORTH KOREA

  • Publication of regulatory amendment to the North Korea Sanctions Regulations; publication of North Korea-related FAQs dated 15 February 2024.

The Treasury Department’s Office of Foreign Assets Control (OFAC) is amending the North Korea Sanctions Regulations to amend or add general licenses to facilitate certain humanitarian and journalistic activities. Specifically, OFAC is amending an existing general licence for non-governmental organisations and adding general licences to authorise certain transactions related to the export and re-export of items authorised by the US Department of Commerce; the supply of certain agricultural products, medicines and medical devices; and certain journalistic activities in North Korea. This regulatory amendment is currently available for public inspection in the Federal Register and will become effective upon publication in the Federal Register on 16 February 2024.

  • OFAC has also published several new FAQs related to North Korea (1160, 1161, 1162, 1163) and has amended FAQs 459, 463, 558.

 

II. EUROPEAN UNION

GUATEMALA

  • On 2 February 2024, Council Decision (CFSP) 2024/457 amending Decision (CFSP) 2024/254 concerning restrictive measures in view of the situation in Guatemala was published in the Official Journal of the European Union.

The Council considers that five persons should be added to the list of natural or legal persons, entities and bodies subject to restrictive measures set out in the Annex to Decision (CFSP) 2024/254.

ZIMBABWE

  • On 2 February 2024, Council Decision (CFSP) 2024/460 extending Decision (CFSP) 2011/101/CFSP until 20 February 2025 concerning restrictive measures in view of the situation in Zimbabwe was published in the Official Journal of the European Union.

TERRORISM

  • Council Decision (CFSP) 2024/628 amending Common Position 2001/931/CFSP on the application of specific measures to combat terrorism was published in the Official Journal of the European Union on 20 February 2024.

RUSSIA

  • On 20 February 2024, Council Decision (CFSP) 2024/633 amending Council 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 the control of the Government was published in the Official Journal of the European Union.
  • On 23 February 2024, Council Decision (CFSP) 2024/746 amending Decision 2014/512/CFSP concerning restrictive measures in response to actions by Russia destabilising the situation in Ukraine was published in the Official Journal of the European Union.

In view of the gravity of the situation, the Council considers it necessary to adopt new restrictive measures. It is proposed to add 27 new entities to the list directly supporting the Russian military-industrial complex in its war of aggression against Ukraine. These entities will be subject to tighter restrictions on the export of dual-use goods and technology, as well as goods and technology likely to enhance Russia’s defence and security sector.

The inclusion of third country entities supplying electronic components to the Russian military complex is also envisaged, along with Russian entities involved in the development and supply of such components.

In addition, it is proposed to expand the list of items under control that contribute to Russia’s military and technological improvement, including items for the development and production of unmanned aerial vehicles. It is planned to impose new restrictions on the export of products that could contribute to the improvement of Russia’s industrial capabilities. It is also proposed to expand the list of partner countries subject to restrictive measures on iron and steel imports, as well as substantially equivalent control measures.

MOLDOVA

  • On 22 February 2024, Council Decision (CFSP) 2024/740 amending Decision (CFSP) 2023/891 concerning restrictive measures against actions destabilising the Republic of Moldova was published in the Official Journal of the European Union.

The Council considers that six persons and one entity should be added to the list of natural or legal persons, entities and bodies set out in Annex I to Regulation (EU) 2023/888.

LIBYA

  • On 26 February 2024, Council Implementing Regulation (EU) 2024/757 implementing Regulation (EU) 2016/44 concerning restrictive measures in view of the situation in Libya was published in the Official Journal of the European Union.

BELARUS

  • On 26 February 2024, Council Implementing Regulation (EU) 2024/768 implementing Article 8a of Regulation (EC) No 765/2006 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.

 

III. UNITED KINGDOM

  • On 1 February 2024 the UK Government, pursuant to The Myanmar (Sanctions) (EU EXIT) Regulations 2019 has added 4 new designations under the Myanmar sanctions regime to the UK Sanction list (“UKSL List”).
  • On 2 February 2024 the UK Government, pursuant to The Libya (Sanctions) (EU EXIT) Regulations 2019 has made an amendment to the UK Sanction list (“UKSL List”) under the Libya sanctions regime.
  • On 6 February 2024 the UK Government, pursuant to The Russia (Sanctions) (EU EXIT) Regulations 2019 has made an amendment to the UK Sanction list (“UKSL List”) of the Russia sanctions regime.
  • On 12 February 2024 the UK Government, pursuant to The Russia (Sanctions) (EU EXIT) Regulations 2019 has added to the UK Sanction list (“UKSL List”) 4 new designations and one amendment under the Russia sanctions regime.
  • On 21 February 2024 the UK Government, pursuant to The Global Human Rights (Sanctions) (EU EXIT) Regulations 2019 has added to the UK Sanction list (“UKSL List”) 6 new designations under the human rights sanctions regime.
  • On 21 February 2024, the UK Government, pursuant to The Democratic Republic of the Congo (Sanctions) (EU EXIT) Regulations 2019 has added to the UK Sanction list (“UKSL List”) 6 new designations under the sanctions regime against the Democratic Republic of the Congo.
  • On 22 February 2024 the UK Government, pursuant to The Belarus (Sanctions) (EU EXIT) Regulations 2019 has added 2 new designations under the Belarus sanctions regime to the UK Sanction list (“UKSL List”).
  • On 22 February 2024 the UK Government, pursuant to The Russia (Sanctions) (EU EXIT) Regulations 2019 has added to the UK Sanction list (“UKSL List”) 50 new designations and new amendments under the Russia sanctions regime.
  • On 27 February 2024 the UK Government, pursuant to The Iran (Sanctions) (EU EXIT) Regulations 2019, has added 5 new designations under the Iran sanctions regime to the UK Sanction list (“UKSL List”).
  • On 27 February 2024 the UK Government under The Yemen (Sanctions) (EU EXIT) Regulations 2019 has added 1 new designation under the Yemen sanctions regime to the UK Sanction list (“UKSL List”).
  • On 28 February 2024, the UK Government made 1 administrative amendment under the Russia sanctions regime and 1 administrative amendment under the Democratic Republic of Congo sanctions regime.

 

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More information:

Lupicinio International Law Firm

C/ Villanueva 29
28001 Madrid
P: +34 91 436 00 90

info@lupicinio.com

 

 

 

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