International sanctions have become a popular foreign policy instrument in an increasingly multipolarised world. Once limited to a few cases, they are now extremely widespread. There is growing evidence that international sanctions are a problem rather than a solution for the achievement of a peaceful international order. The main causes are the overuse of sanctions and their increasing use as an instrument of power. They have become a key element in the geopolitics of the international chessboard. Abusive use has led to an increase in 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 has an international component, 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 in some way.
I. EUROPEAN UNION
- On 20 March 2023, Council DECISION (CFSP) 2023/646 of 20 March 2023 implementing DECISION 2011/1235/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.
In view of the gravity of the situation, the Council considers that eight persons and one entity should be added to the list of natural and legal persons, entities and bodies subject to restrictive measures set out in the Annex to DECISION 2011/1235/CFSP and therefore amends Decision 2011/1235/CFSP accordingly.
II. UNITED STATES OF AMERICA
- On 3 March 2023, by virtue of Executive Order (E.O.) 13818, three individuals have been designated as follows.
The Office of Foreign Assets Control has sanctioned three Russian individuals for their alleged involvement in human rights violations committed against opposition human rights defender, writer and historian Vladimir Kara-Murza (Kara-Murza).
- On 1 March 2023, the Treasury Department’s Office of Foreign Assets Control (OFAC) sanctioned three entities and two individuals under Executive Order (E.O.) 13687.
OFAC sanctioned three entities and two individuals that allegedly generated illicit revenues in support of the government of the Democratic People’s Republic of Korea (DPRK). Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson stated: “The DPRK’s illegal weapons of mass destruction and ballistic missile programmes threaten international security and regional stability” and added: “The United States remains committed to targeting the regime’s global illicit networks that generate revenue for these destabilising activities.“
- As of 2 March 2023, by virtue of Executive Order (E.O) 14059, eight companies have been designated.
The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated eight individuals under Executive Order (EO) 14059 for links to funding related to 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. This action is the result of collaboration between the US Treasury Department, the Government of Mexico and the US Drug Enforcement Administration (DEA).
“As the CJNG has consolidated territory over the past decade, it has added other crimes to its core drug trafficking activity”, said OFAC Director Andrea M. Gacki. She further added: “In tourist destinations such as Puerto Vallarta, the CJNG has been heavily involved in timeshare fraud, often targeting US citizens. This crime, which can defraud victims of their life savings, is another important source of revenue for the cartel and bolsters its overall criminal enterprise. Today’s action unmasks this CJNG scheme and also serves as a warning to potential victims, many of whom are elderly.”
The eight companies designated today, which are directly or indirectly connected to the timeshare fraud. These companies claim to be engaged in financial or real estate services. Five of them – Servicios Administrativos Fordtwoo, S.A. de C.V., Integración Badeva, S.A. de C.V., JM Providers Office, S.A. de C.V., Promotora Vallarta One, S.A. de C.V., and Recservi, S.A. de C.V. – are based in or near Puerto Vallarta, Jalisco, Mexico. Servicios Administrativos Fordtwoo, S.A. de C.V. has also made direct payments to CJNG members.
Puerto Vallarta is a strategic location for CJNG drug trafficking and other illicit activities. OFAC has taken multiple actions against CJNG actors in Puerto Vallarta, including those linked to nightclubs, bars, and restaurants. In addition, OFAC has designated high-ranking CJNG members Carlos Andrés Rivera Varela (alias “La Firma”), Francisco Javier Gudino Haro (alias “La Gallina”) and Julio César Montero Pinzón (alias “El Tarjetas”), who are part of a CJNG enforcement group based in Puerto Vallarta that prepares assassinations of rivals and politicians using high-powered weaponry.
The remaining companies designated today – Corporativo Title I, S.A. de C.V., Corporativo TS Business Inc, S.A. de C.V., and TS Business Corporativo, S.A. de C.V. – are based in Guadalajara, Jalisco, Mexico.
These eight companies are being designated under Executive Order (E.O.) 14059 as being owned, controlled or directed by, or having acted or purported to act for or on behalf of, directly or indirectly, CJNG.
- On 15 March 2023, OFAC, pursuant to BALKANS Executive Order (E.O.) 14033, designated three (3) natural persons in Bosnia and Herzegovina pursuant to Executive Orders (E.O.) 14033 and 14059 as follows.
“The three individuals designated today pose a threat to regional stability, institutional confidence, and the aspirations of those seeking democratic governance in the Western Balkans”, said Treasury Under Secretary for Terrorism and Financial Intelligence Brian E. Nelson. “The United States will continue to pursue those who perpetuate corruption and undermine the post-war arrangements and institutions established as part of the hard-won Dayton Peace Agreement.”
- On 24 June 2023, OFAC, pursuant to Executive Order (E.O.) 14038, added three (3) entities and nine (9) individuals to the SDN list and identified a presidential aircraft as blocked property.
“Lukashenka’s authoritarian regime relies on state-owned enterprises and key officials to generate substantial revenues that enable oppressive acts against the Belarusian people”, said Treasury Under Secretary for Terrorism and Financial Intelligence Brian Nelson. He added: “We remain committed to imposing costs on the Lukashenka regime for its suppression of democracy and support for Putin’s war.”
At the same time and in celebration of Belarusian Freedom Day, the State Department announces measures to impose visa restrictions on 14 other individuals, including regime officials.
- As of 2 March 2023, OFAC, pursuant to Executive Order (E.O.) 13846, has added six entities engaged in the transportation or sale of Iranian petroleum products or petrochemicals to the list. In addition, it has identified 20 vessels as owned by or having interests related to these entities.
- As of 8 March 2023, the Treasury Department’s Office of Foreign Assets Control (OFAC), in cooperation with the European Union, the United Kingdom and Australia, is sanctioning a number of Iranian regime officials and entities.
Among them are two senior officials in the Iranian prison system who have allegedly been responsible for serious human rights abuses against women and girls. OFAC is also taking action against the top commander of the Iranian military and a senior leader of the Islamic Revolutionary Guard Corps (IRGC), as well as an Iranian official who played a key role in the regime’s efforts to block access to the internet. Finally, OFAC sanctions three Iranian companies and their leaders for allowing the Iranian Security Forces’ violent repression of peaceful protesters, including many women and girls.
These designations are made under Executive Order (E.O.) 13553, which authorises the imposition of sanctions on certain persons in connection with alleged human rights violations by the Government of Iran, and Executive Order (E.O.) 13846, which authorises sanctions on persons engaging in censorship or other activities with respect to Iran. This is the tenth round of OFAC designations targeting the Iranian regime for its crackdown on protests that began in September 2022.
- As of 9 March 2023, 39 entities have been added to the list of those sanctioned under Executive Order (E.O.) 13846.
These entities have been sanctioned for constituting a network of: “shadow banking”. One of several multi-jurisdictional illicit financing schemes that grant sanctioned Iranian entities, such as Persian Gulf Petrochemical Industry Commercial Co. (PGPICC) and Triliance Petrochemical Co. (Triliance), access to the international financial system and allow them to trade with foreign customers. The Iranian bureaux de change set up shell companies abroad to allow trading on behalf of their Iranian clients, with foreign exchange transactions maintained through internal books of account. PGPICC is the trading arm of the sanctioned Iranian petrochemical conglomerate Persian Gulf Petrochemical Industries Company (PGPIC), which generates the equivalent of tens of billions of dollars annually for the Iranian regime.
- As of 9 March 2023, OFAC, pursuant to Executive Order (E.O) 13382, has added to the list a network of companies and an individual for supporting Iranian UAV procurement efforts.
This PRC-based network is responsible for the sale and shipment of thousands of aerospace components, including components that can be used for UAV applications, to the Iran Aircraft Manufacturing Industrial Company (HESA).
- On March 21, 2023, OFAC in coordination with the Federal Bureau of Investigation (FBI), pursuant to Executive Order (E.O.) 13382, has designated four entities and three individuals.
Four entities and three individuals have been designated in Iran and Turkey for their involvement in the procurement of equipment, including European-origin unmanned aerial vehicle (UAV) engines in support of Iran’s weapons and UAV programmes. This network operates on behalf of Iran’s Ministry of Defence and Armed Forces Logistics (MODAFL), which oversees several companies involved in the development of UAVs and ballistic missiles.
- On 24 March 2023, OFAC, by virtue of Executive Order (E.O.) 14014, added two (2) natural persons and six (6) entities to the SDN List.
These two individuals and six designated entities are connected to the Burmese military who have allegedly enabled the military regime’s aggression by importing, storing and distributing aviation fuel to the Burmese military. This comes as the military regime prepares to celebrate the 78th Armed Forces Day.
III. UNITED KINGDOM
DEMOCRATIC REPUBLIC OF CONGO
- As of 7 March 2023 the UK Government, under The Central African Republic (Sanctions) (EU Exit) Regulations 2020, has added one (1) new individual.
- On 10 March 2023 the UK Government, under the Regime: Russia (Sanctions) (Eu Exit) Regulations 2019, has added three (3) new individuals to the UK Sanctions List (“UKSL List”).
- On 27 June 2023 the UK Government, under the Regime: Myanmar Sanctions Regime has added two (2) new individuals and three (3) entities to the UK Sanction List (“UKSL List”).
- On 20 March 2023 the UK Government, pursuant to The Iran (Sanctions) (Human rights) (EU EXIT) Regulations 2019 has added seven (7) new individuals to the UK Sanction list (“UKSL List”).
- On 10 March 2023 the UK Government, pursuant to The Iran (Sanctions) (Human rights) (EU EXIT) Regulations 2019 has added to the UK Sanction list (“UKSL List”) one (1) new individuals and two (2) entities.
- On 8 March 2023 the UK Government, pursuant to The Iran (Sanctions) (Human rights) (EU EXIT) Regulations 2019 has added five (5) new individuals to the UK Sanction list (“UKSL List”).
In Madrid, 31 March 2023
International Trade and Sanctions Department