INTERNATIONAL SANCTIONS JUNE 2022

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 3 June 2022, Council DECISION (CFSP) 2022/883 of 3 June 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.

In view of the gravity of the situation, the Council considers that 65 persons and 18 entities
should be added to the list of persons, entities and bodies subject to restrictive measures set out in the Annex to Decision 2014/145/CFSP.

  • On 3 June 2022, Council DECISION (CFSP) 2022/884 of 3 June 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.

In view of the gravity of the situation, and in response to Russia’s actions destabilising the situation in Ukraine, it is necessary, in line with the fundamental rights and freedoms recognised by the Charter of Fundamental Rights, in particular the right to freedom of expression and information as recognised in Article 11 thereof, to introduce further restrictive measures to suspend the broadcasting activities of those media in, or directed at, the Union. The measures should be maintained until the aggression against Ukraine ceases and until the Russian Federation and its associated media cease propaganda actions against the Union and its Member States.

  • On 3 June 2022, Council DECISION (CFSP) 2022/885 of 3 June 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 June 2022, Council DECISION (CFSP) 2022/962 of 20 June 2022 amending DECISION 2014/386/CFSP concerning restrictive measures in response to the illegal annexation of Crimea and Sevastopol was published in the Official Journal of the European Union.
  • On 24 June 2022, Council DECISION (CFSP) 2022/995 of 24 June 2022 concerning restrictive measures in view of actions by Russia destabilising Ukraine has been published in the Official Journal of the European Union.

BELARUS

  • On 3 June 2022, Council DECISION (CFSP) 2022/881 of 3 June 2022 implementing 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.

In view of the gravity of the situation in Belarus and the continuing human rights violations and repression of civil society and democratic opposition, it is appropriate to include 12 persons and 8 entities on the list of natural and legal persons, entities and bodies subject to restrictive measures set out in Annex I to Decision 2012/642/CFSP.

  • On 3 June 2022, Council DECISION (CFSP) 2022/882 of 3 June 2022 implementing 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.

In view of the gravity of the situation, the list of Belarusian credit institutions and their Belarusian subsidiaries subject to restrictive measures on the provision of specialised financial messaging services should be extended. The list of entities subject to restrictions on authorisations for the sale, supply, transfer or export of dual-use items and technology, and of items and technology which could contribute to the military and technological improvement of Belarus, or to the development of its defence and security sector, should also be extended.

DAESH

  • On 20 June 2022, Council DECISION (CFSP) 2022/950 of 20 June 2022 amending Decision (CFSP) 2016/1693 concerning restrictive measures against ISIL (Da’esh) and Al-Qaida and individuals, groups, undertakings and entities associated with them was published in the Official Journal of the European Union.

In view of the continuing threat posed by ISIL (Da’esh) and Al-Qaida and individuals, groups, undertakings and entities associated with them, three individuals and one group should be added to the list of individuals, groups, undertakings and entities set out in the Annex to Decision (CFSP) 2016/1693.

IRAN

  • On 28 June 2022, Council DECISION (CFSP) 2022/1019 of 27 June 2022 amending DECISION 2010/413/CFSP concerning restrictive measures against Iran was published in the Official Journal of the European Union.

DEMOCRATIC REPUBLIC OF THE CONGO

  • On 28 June 2022, Council Implementing Decision (CFSP) 2022/1020 of 27 June 2022 implementing Council Decision 2010/788/CFSP concerning restrictive measures in view of the situation in the Democratic Republic of the Congo was published in the Official Journal of the European Union.

 

2. UNITED STATES

RUSSIA

  • On 2 June 2022, 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, seventeen (17) individuals, sixteen (16) entities, six (6) vessels and three (3) aircraft have been added to the SDN list.
  • On 28 June 2022, under Executive Order (E.O.) 14024, which authorises the imposition of sanctions against Russia for its harmful foreign activities, including violation of basic principles of international law such as respect for the territorial integrity of other states, fifty-seven (57) individuals and one hundred and twelve (112) entities have been added to the SDN list.

The US Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions on individuals and entities, including State Corporation Rostec, “a huge Russian state-owned enterprise formed to consolidate Russia’s technological, aerospace and military expertise” and its major holdings and subsidiaries.

In addition, Executive Order (E.O.) 14068 of 11 March 2022 (“Prohibition on Certain Imports, Exports, and New Investments with Respect to Continued Aggression by the Russian Federation”) extends the prohibitions of section 1(a)(i) of E.O. 14068 to Russian-origin gold.

Accordingly, the importation into the United States of Russian-origin gold is prohibited from the Russian Federation, except to the extent provided by law, or unless authorised by the Office of Foreign Assets Control. This determination excludes Russian Federation-origin gold of Russian Federation origin that was outside the Russian Federation prior to the effective date of this determination.

NARCOTICS

  • As of 2 June 2022, pursuant to the Illicit-drugs-EO, six (6) individuals of Mexican nationality have been added to the SDN list.

The US Treasury Department’s Office of Foreign Assets Control (OFAC) designated six individuals under Executive Order (EO) 14059 for their support or actions on behalf of the Jalisco Cartel – New Generation (CJNG), a violent organisation based in Mexico that traffics a significant portion of the fentanyl and other deadly drugs entering the United States. Today’s action is the result of collaboration between the U.S. Department of the Treasury, the Government of Mexico and the U.S. Drug Enforcement Administration (DEA). US Customs and Border Protection has also provided support in this case.

“Violence and corruption have been central to the growth of the CJNG over the past decade,” said Treasury Under Secretary for Terrorism and Financial Intelligence Brian E. Nelson. “These two forces have fuelled the cartel’s territorial expansion, and with it a greater ability to traffic deadly drugs into the United States. Meanwhile, support networks help fugitive CJNG leaders remain underground and evade justice. Treasury will continue to work with U.S. partners and the Mexican government to attack the violence, corruption, and facilitation that underpin CJNG’s power.”

Severo Flores Mendoza (Flores Mendoza) is a corrupt Mexican municipal and national police official who provides police information to the CJNG in exchange for bribes. Flores Mendoza is currently the police chief of Ameca, Jalisco, Mexico. He is also the coordinator of police chiefs for the Valles region of Jalisco, which is composed of 14 municipalities, including Ameca. This region is located in the area between Guadalajara and Puerto Vallarta. Flores Mendoza has held other police positions in Jalisco over the past decade. In 2014, Flores Mendoza failed a confidence test applied to police officers, but has continued his career in law enforcement.

Julio César Montero Pinzón (Montero Pinzón) is part of a violent CJNG law enforcement group based in Puerto Vallarta that orchestrates assassinations of rivals and politicians using high-powered weaponry. Montero Pinzón, a Mexican national, is a close associate of Carlos Andrés Rivera Varela (alias “La Firma”) and Francisco Javier Gudino Haro (alias “La Gallina”), who have already been named. Puerto Vallarta is a strategic stronghold of the CJNG, not only for drug trafficking but also for money laundering and extortion.

Saúl Alejandro Rincón Godoy (Rincón Godoy) (alias “Chopa”) was a senior member of the CJNG who died recently in Puerto Vallarta after a confrontation with Mexican authorities. Prior to his death, Rincón Godoy acted as an intermediary between CJNG leader Rubén Oseguera Cervantes (Osegura Cervantes, alias “Mencho”) and high-level members of the cartel, and was linked to murders carried out by the CJNG in Puerto Vallarta. He also led a support network for Osegura Cervantes, which included members of his family who are now being named: Esther Godoy Arellano (mother), Angelberto Rincón Godoy (brother), Julio Efraín Rincón Godoy (brother), and Moisés González Anguiano (brother-in-law), recently arrested by Mexican authorities.

BALCANES

  • On 6 June 2022 OFAC, by virtue of BALKANS Executive Order (E.O.) 14033 (“Executive Order”), has added two (2) natural persons of Bosnian nationality to the SDN List.

TERRORISM

  • On 15 June 2022 OFAC, pursuant to Secondary Sanctions risk: section 1(b) of Executive Order 13224, has added three (3) natural persons to the SDN list in connection with the Russian imperialist movement: Section 1(b) of Executive Order 13224″, has added three (3) natural persons to the SDN list in connection with the Russian imperialist movement.

The US Treasury Department’s Office of Foreign Assets Control (OFAC) is designating two key supporters of the ethnically motivated violent extremist group known as the Russian Imperial Movement (RIM) pursuant to Executive Order (EO) 13224, as amended. The RIM was previously designated by the US State Department as a Specially Designated Global Terrorist Organisation (SDGT) on 7 April 2020 for providing training for acts of terrorism. Coinciding with today’s OFAC action, the US State Department also designated an individual for posing a significant risk of committing acts of terrorism.

“The Russian Imperial Movement has sought to raise and move funds using the international financial system with the intent to build a global network of violent groups that promote extremist views and subvert democratic processes,” said Treasury Under Secretary for Terrorism and Financial Intelligence Brian E. Nelson. “RIM and its supporters continue to exacerbate Russia’s war of aggression in Ukraine through their fundraising efforts. We will continue to identify opportunities to disrupt racially and ethnically motivated violent extremist networks that seek to train, fundraise, or recruit across borders and prevent the international financial system from becoming an incubator for violent extremist activities.”

Today’s action implements the National Strategy to Counter Domestic Terrorism and specifically targets a group of Racially and Ethnically Motivated Violent Extremists (REMVE) who have approached individuals in the United States. OFAC, in coordination with the State Department, other components of the federal government, and foreign partners, will continue to identify entities and individuals that meet the criteria to be designated as SDGTs in accordance with the national strategy.

IRAN

  • On 16 June 2022 OFAC, by virtue of IRAN Executive Order (E.O.) 13846 (“Executive Order”), has added two (2) natural persons and nine (9) entities to the SDN List.

NICARAGUA

  • On 17 June 2022 OFAC, by virtue of Executive Order (E.O.) 13851, has added one (1) natural person and one (1) entity to the SDN List.

The US Treasury Department’s Office of Foreign Assets Control (OFAC) designated the Nicaraguan state-owned mining company Empresa Nicaragüense de Minas (ENIMINAS), as well as an official of the Government of Nicaragua, under Executive Order (EO) 13851.

The Ortega-Murillo regime rigged the Nicaraguan presidential elections last November by arbitrarily imprisoning the political opposition, blocking political parties, shutting down independent media and intimidating civil society. They are deepening their relationship with Russia as it wages war against Ukraine, while using gold revenues to further oppress the Nicaraguan people and engage in activities that threaten the security of the hemisphere. The United States will continue to use all available tools to promote accountability and compliance with international norms by the Ortega-Murillo regime.

“As the Ortega-Murillo regime becomes increasingly involved with Russia and continues to fill its coffers with the significant revenues exploited from Nicaragua’s gold sector, the regime has turned its back on the Nicaraguan people, neglecting their livelihoods for regime profits,” said Treasury Under Secretary for Terrorism and Financial Intelligence Brian E. Nelson. “The United States continues to stand with the Nicaraguan people against the Ortega-Murillo regime’s unjust imprisonment of political opponents and sustained assault on Nicaragua’s democracy.”

In 2017, the Nicaraguan government created the state-owned company ENIMINAS to consolidate its control over the Nicaraguan mining sector. One of the company’s functions is to regulate gold mining by issuing land concessions to domestic and foreign companies, which have several joint ventures with private firms. Senior members of the Ortega-Murillo regime have benefited enormously from the increase in Nicaragua’s gold exports in recent years, due in large part to the huge role ENIMINAS has played in channelling profits to private sector partners and bribes to regime insiders. Nicaragua’s gold exports have increased dramatically in recent years. In 2021, Nicaragua’s gold exports to the United States increased by thirty percent, totalling over $744 million. These exports accounted for seventy-nine percent of all gold exports from Nicaragua during the year.

OFAC designated ENIMINAS pursuant to E.O. 13851 as being owned or controlled by, or acting or purporting to act for or on behalf of, directly or indirectly, Ruy Delgado Lopez.  In conjunction with this action, OFAC issued Nicaraguan General Licence (GL) 3, which provides a time-limited authorisation allowing US persons to settle transactions related to ENIMINAS. OFAC also issued associated guidance noting that foreign persons are not at risk of being sanctioned for engaging in the activities authorised by GL 3.

Ruy Delgado López (López) is the president of the board of directors of the state-owned company ENIMINAS, and is being designated, pursuant to EO 13851, for being an official of the Government of Nicaragua or having served as an official of the Government of Nicaragua at any time on or after 10 January 2007.  The Treasury Department has previously designated two other individuals who held this same position, Ramón Humberto Calderón Vindell in January 2022 and Francisco López Centeno in July 2018.

López is being designated as being an official of the Government of Nicaragua or having served as an official of the Government of Nicaragua at any time on or after 10 January 2007. ENIMINAS is being designated as being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Lopez.

 

3.  UNITED KINGDOM

AL-QAEDA

  • On 14 June 2022 the UK Government, pursuant to Regime: ISIL (Da’esh) and Al Qaida Sanctions Regime has added six (6) new individuals to the UK Sanction list (‘UKSL List’).

RUSSIA

  • On 16 June 2022 the UK Government, under the Regime: Russia (Sanctions) (Eu Exit) Regulations 2019, added twelve (12) new individuals to the UK Sanctions List (“UKSL List”).
  • On 29 June 2022 the UK Government, under the Regime: Russia (Sanctions) (Eu Exit) Regulations 2019, added thirteen (13) new individuals to the UK Sanctions List (“UKSL List”).

MYANMAR

  • On 16 June 2022 the UK Government, pursuant to Regime: Myanmar Sanctions Regime has added six (6) new individuals to the UK Sanction list (“UKSL List”).

SYRIA

  • On June 29, 2022 the UK Government, under the Syria Sanctions Regime has added seven (7) new individuals to the UK Sanction list (“UKSL List”).

 

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In Madrid, 30 June 2022

International Trade and Sanctions Department

Lupicinio International Law Firm