INTERNATIONAL SANCTIONS JANUARY 2022

2022-02-01 International Sanctions Newsletters

EUROPEAN UNION

DAESH and Al-Qaida-related entities

On 4 January 2022, COMMISSION IMPLEMENTING REGULATION (EU) 2022/5 of 4 January 2022 amending for the 325th 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 was published in the Official Journal of the European Union:
Having regard to Council Regulation (EC) No 881/2002 of 27 May 2002 imposing certain specific restrictive measures directed against certain persons and entities associated with ISIL (Da’esh) and Al-Qaida organisations (1), and in particular Article 7(1)(a) and Article 7a (1) thereof

Annex I to Regulation (EC) No 881/2002 is amended in accordance with the Annex to this Regulation.

In Annex I to Regulation (EC) No 881/2002, 7 individuals shall be added under the heading ‘Natural persons’.
Under the heading ‘Legal persons, groups and entities’ in Annex I to Regulation (EC) No 881/2002, 9 natural persons shall be added. Date of designation referred to in Article 7d(2)(i): 29.12.2021″.
On 19 January 2022, COMMISSION IMPLEMENTING REGULATION (EU) 2022/84 of 19 January 2022 amending for the 327th 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 was published in the Official Journal of the European Union:
Having regard to Council Regulation (EC) No 881/2002 of 27 May 2002 imposing certain specific restrictive measures directed against certain persons and entities associated with ISIL (Da’esh) and Al-Qaida organisations (1), and in particular Articles 7(1)(a) and 7a (5) thereof;

In Annex I to Regulation (EC) No 881/2002, under the heading ‘Legal persons, groups and entities’, the entries for 3 natural persons shall be deleted.

BELARUS

On 19 January 2022, COUNCIL DECISION (CFSP) 2022/52 of 13 January 2022 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.

Whereas:

(1) On 31 July 2014, the Council adopted Decision 2014/512/CFSP (1).

(2) On 19 March 2015, the European Council agreed that the necessary steps would be taken to clearly link the duration of the restrictive measures to the full implementation of the Minsk agreements, taking into account that full implementation was scheduled for 31 December 2015.

(3) On 12 July 2021 the Council adopted Decision (CFSP) 2021/1144 (2) extending Decision 2014/512/CFSP until 31 January 2022 in order to allow for the possibility of reassessing the implementation of the Minsk agreements.

(4) Having assessed the implementation of the Minsk arrangements, the Council considers that it is appropriate to extend Decision 2014/512/CFSP for a further six months, so as to give the Council the possibility to reassess its implementation.

(5) Decision 2014/512/CFSP should therefore be amended accordingly.

NICARAGUA

On 10 January 2020, COUNCIL IMPLEMENTING DECISION (CFSP) 2022/23 of 10 January 2022 implementing Decision 2013/798/CFSP concerning restrictive measures against the Central African Republic was published in the Official Journal of the European Union.

5 natural persons shall be added to the list set out in Part A (Persons) of the Annex to Decision 2013/798/CFSP:

CENTRAL AFRICAN REPUBLIC

On 10 January 2022, COUNCIL DECISION (CFSP) 2022/24 of 10 January 2022 amending Decision (CFSP) 2019/1720 concerning restrictive measures in view of the situation in Nicaragua has been published in the Official Journal of the European Union.
The title of the table is replaced by the following: ‘A. Natural persons referred to in Articles 1(1) and 2(1)”. Seven natural persons shall be added.
The following heading and table shall be added: “B. Legal persons, entities and bodies referred to in Article 2(1)”, 3 legal persons.

UNITED STATES OF AMERICA

BOSNIA-HERZEGOVINA

As of 5 January 2022 OFAC, pursuant to Executive Order (E.O.) has14033 added to the SDN List one (1) natural person and one (1) entity of Bosnian nationality, “[f]or undermining the stability of the Western Balkans region through corruption and threats to long-standing peace agreements”.

All assets and interests in assets of these persons that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. In addition, all entities that are owned, directly or indirectly, 50% or more in the aggregate by one or more of these persons are also blocked. OFAC regulations generally prohibit all transactions by U.S. persons or within (or in transit through) the United States involving property or interests in property of designated persons.

NICARAGUA

As of 10January 2022, OFAC, by Executive Order (E.O.)13851, has added six (6) Nicaraguan nationals to the SDN list, “[T]he Ortega-Murillo regime continues its subjugation of democracy by conducting sham elections, silencing peaceful opposition, and detaining hundreds of people as political prisoners. The following six individuals are members of the Ortega-Murillo regime. They are designated for being officials of the Government of Nicaragua or for having served as officials of the Government of Nicaragua at any time since 10 January 2007“.

All assets and interest on assets of these persons that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. In addition, all entities that are owned, directly or indirectly, 50% or more in the aggregate by one or more of these persons are also blocked. OFAC regulations generally prohibit all transactions by U.S. persons or within (or in transit through) the United States involving property or interests in property of designated persons.

NORTH KOREA

As of 12January 202,2 OFAC, by Executive Order (E.O.)13382, has added to the SDN list one (7) natural persons of North Korean nationality, “[f]or acquiring goods for the DPRK’s weapons of mass destruction (WMD) and ballistic missile programmes”.

RUSSIA

As of 12January 202,2 OFAC, by Executive Order (E.O.)13382, has added to the SDN List one (1) natural person and one (1) entity of Russian nationality, “for having engaged in activities or transactions that have materially contributed to the DPRK’s proliferation of weapons of mass destruction or their means of delivery”.

On 20 January 2021, OFAC, pursuant to Executive Order (E.O.) 14024, added four (4) natural persons of Russian nationality to the SDN List, “[f]or being responsible for or complicit in, or for having participated or attempted to participate directly or indirectly in, interfering in an election of the United States or another foreign government, for or on behalf of, or for the benefit of, directly or indirectly, the Government of the Russian Federation”.

LEBANON

On 18 January 202,2 OFAC, pursuant to Executive Order (E.O.) 13224, which targets terrorists, leaders and officials of terrorist groups, and those who provide support to terrorists or acts of terrorism, added to the SDGT list three (3) natural persons and one (1) entity of Lebanese nationality, “[b]y having materially assisted, sponsored, or provided financial, material or technological support, or goods or services to or in support of Hizbollah. “.

On 21 January 202,2 OFAC, by virtue of Executive Order (E.O.) 13224, added to the SDGT list two (2) natural persons and seven (7) entities of Lebanese nationality, ‘having materially assisted, sponsored or provided financial, material or technological support, or goods or services to, or in support of, Hezbollah’.

In addition, engaging in certain transactions with the persons and entities designated today carries the risk of secondary sanctions under EO 13224, as amended. Under this authority, OFAC may prohibit or impose strict conditions on the opening or maintenance in the United States of a correspondent or payable-through account with a foreign financial institution that knowingly conducted or facilitated any significant transaction on behalf of a specially designated global terrorist.

GERMANY

On 21 January 202,2 OFAC, pursuant to Executive Order (E.O.) 13224, which targets terrorists, leaders and officials of terrorist groups, and those who provide support to terrorists or acts of terrorism, added to the SDGT list one (1) natural person and one (1) entity of German nationality, “for having materially assisted, sponsored or provided financial, material or technological support, or goods or services to or in support of Hezbollah”.

ZAMBIA

On 21 January 202,2 OFAC, pursuant to Executive Order (E.O.) 13224, which targets terrorists, leaders and officials of terrorist groups, and those who provide support to terrorists or acts of terrorism, added two (2) entities of Zambian nationality to the SDGT list, “for having materially assisted, sponsored, or provided financial, material or technological support, or goods or services to or in support of Hezbollah”.

UNITED KINGDOM

LIBIYA

As of 12January 2022 the UK Government, pursuant to The Libya (Sanctions)(EU Exit) Regulations 2020 has added to the UK Sanctions List (‘UKSL List’) one (1) natural person of Libyan nationality, ‘[T]here are reasonable grounds to suspect that he has been involved in activities on behalf of the former regime of Muammar Gaddafi, implementing the repressive policies of that regime or related thereto, through his involvement in the procurement and coordination of foreign armed mercenary personnel on behalf of that regime, in violation of the arms embargo imposed by paragraph 9 of UN Security Council Resolution 1970. In addition/alternatively, there are reasonable grounds to suspect that this person attempted to spread disinformation in Libya and opposition to the UN-led political process in Libya threatens the peace, stability and security of Libya or undermines its transition to a democratic, peaceful and independent country”. Sanctions imposed on individuals on the USKL list include a travel ban and an assets freeze.

RUSSIA

On 13 January 2022 the British Government, under The Global Human Rights Sanctions Regulations 2020 has added to the UK Sanctions List (“UKSL List“) two (2) natural persons of Russian nationality, “[f]or being responsible for the murder of Alexander Litvinenko by deliberate poisoning with polonium-210 in November 2006. This action constitutes a grave violation of the right to life”. Sanctions imposed on individuals on the USKL list include a travel ban and an asset freeze.

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Madrid, 31 January 2022

International Trade and Sanctions Department

Lupicinio International Law Firm