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 21 July 2022, Council DECISION (CFSP) 2022/1271 of 21 July 2022 amending Decision 2014/512/CFSP concerning restrictive measures in view of actions by Russia destabilising the situation in Ukraine has been published in the Official Journal of the European Union.
- On 21 July 2022, Council DECISION (CFSP) 2022/1272 of 21 July 2022 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine was published in the Official Journal of the European Union.
- On 21 July 2022, Council DECISION (CFSP) 2022/1276 of 21 July 2022 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine was published in the Official Journal of the European Union.
SYRIA
- On 21 July 2022, Council Implementing Decision (CFSP) 2022/1277 of 21 July 2022 implementing Decision 2013/255/CFSP concerning restrictive measures against Syria was published in the Official Journal of the European Union.
2. UNITED STATES
ANTI-NARCOTICS
- On 7 July 2022, an individual is added to the national narcotics watch list. The US Treasury Department’s Office of Foreign Assets Control (OFAC) designated an individual involved in trafficking high-calibre firearms from the United States to one of Mexico’s most powerful drug trafficking organisations.
The action is the result of ongoing efforts by US agencies and the Government of Mexico to disrupt the acquisition of weapons by Mexican drug trafficking organisations, including from the United States. This action would not have been possible without the cooperation and support of the Government of Mexico, the Department of Homeland Security’s Homeland Security Investigations (HSI) division and the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF).
“CJNG’s power and violence are only possible because of its ability to obtain high-powered weapons, which are used to protect drug trafficking routes, territory, and other illicit assets,” said Treasury Under Secretary for Terrorism and Financial Intelligence Brian E. Nelson. “Treasury is actively pursuing those who support and supply criminal and drug trafficking organisations, especially those involved in the production and distribution of synthetic opioids that claim the lives of tens of thousands of Americans each year.”
IRAN
- On 6 July 2022, Executive Order (E.O) 13846, authorising the imposition of sanctions against Iran for ”international sanctions evasion network in support of Iran’s petrochemical sales” added two (2) individuals, thirteen (13) entities and two (2) vessels to the SDN list.
The US Treasury Department’s Office of Foreign Assets Control (OFAC) sanctioned an international network of individuals and entities that has used a network of Gulf-based front companies to facilitate the delivery and sale of hundreds of millions of dollars in Iranian oil and petrochemical products from Iranian companies to East Asia.
“While the United States is committed to reaching an agreement with Iran that seeks a mutual return to compliance with the Joint Comprehensive Plan of Action, we will continue to use all of our authorities to enforce sanctions on the sale of Iranian oil and petrochemical products,” said Treasury Under Secretary for Terrorism and Financial Intelligence Brian E. Nelson.
As a result of the action, all assets and interests in assets of these targets that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC. In addition, any entity that is owned, directly or indirectly, 50% or more by one or more blocked persons is also blocked. OFAC regulations generally prohibit all transactions by U.S. persons or within the United States (including transactions in transit through the United States) involving property or interests in property of blocked or designated persons.
In addition, persons engaging in certain transactions with the persons and entities designated today may be subject to sanctions or enforcement action. In addition, unless an exception applies, any foreign financial institution that knowingly facilitates a material transaction for any of today’s designated persons or entities could be subject to US sanctions.
3. UNITED KINGDOM
RUSSIA
- On 4 July 2022 the UK Government has added six (6) natural persons and one (1) entity to the UK Sanctions List (“UKSL List”) under the Regime: Russia (Sanctions) (Eu Exit) Regulations 2019.
- On 5 July 2022 the UK Government, under the Regime: Russia (Sanctions) (Eu Exit) Regulations 2019, has added to the UK Sanctions List (“UKSL List”) two (2) natural persons.
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In Madrid, 31 July 2022
International Trade and Sanctions Department
