International Sanctions March 2024

I. EUROPEAN UNION

RUSSIA

  • On 4 March 2024, Council Decision (CFSP) 2048/828 amending Decision 2014/119/CFSP concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in Ukraine was published in the Official Journal of the European Union.

Decision 2014/119/CFSP has been amended with two key adjustments. Firstly, it is established that the decision will apply until 6 March 2025. Secondly, amendments are made to the annex to the decision, changing the wording concerning the rights of defence and the right to an effective remedy.

  • On 12 March 2024, Council Decision (CFSP) 2024/847 amending Decision 2014/146/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.

The Decision follows a review by the Council of the individual designations contained in the Annex to Decision 2014/145/CFSP, which indicates that the information concerning 97 persons and 9 entities should be updated. In addition, the entries relating to nine deceased persons should be deleted from that Annex, as well as the entries relating to three other persons.

SOMALIE

  • On 18 March 2024, Council Decision 2024/882/CFSP amending Decision 2010/231/CFSP concerning restrictive measures against Somalia was published in the Official Journal of the European Union.

Decision 2024/882/CFSP amends Decision 2010/231/CFSP by changing the name of the Decision to “Council Decision 2010/231/CFSP of 26 April 2010 concerning restrictive measures in view of the situation in Somalia” and by replacing Article 1.

HUMAN RIGHTS

  • On 22 March 2024, Council Decision 2024/951/CFSP amending Decision 2020/1999/CFSP concerning restrictive measures against serious violations and abuses of human rights was published in the Official Journal of the European Union.

Article 1 of Decision 2020/1999/CFSP has been amended to include 33 persons and two entities on the list of natural or legal persons, entities and bodies subject to restrictive measures in the Annex to the Decision.

TERRORISM

  • On 25 March 2024, Council Decision 2024/953/CFSP amending Decision 2016/1693/CFSP 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.

An amendment has been made to Article 1 of Decision 2016/1693/CFSP by which one person and a group of persons are included in the list of natural or legal persons, entities and bodies subject to restrictive measures set out in the Annex to that Decision.

BOSNIA AND HERZEGOVINA

  • On 25 March 2024, Council Decision 2024/955/CFSP amending Decision 2011/173/CFSP concerning restrictive measures in view of the situation in Bosnia and Herzegovina and extending these measures until 31 March 2026 was published in the Official Journal of the European Union.

 

II. UNITED STATES

TERRORISM

  • On 2 March 2024, by virtue of 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 5 March 2024, pursuant to Executive Order (E.O) 14093, two individuals and five entities have been added to OFAC’s sanctioned list.

The Treasury Department’s Office of Foreign Assets Control (OFAC) designated two individuals and five entities associated with the Intellexa Consortium for their role in developing, operating, and distributing commercial spyware used to target Americans, including government officials, journalists, and political experts. The proliferation of commercial spyware poses clear and growing security risks to the United States and has been misused by foreign actors to enable human rights abuses and the targeting of dissidents around the world for reprisal and retaliation.

  • On 11 March 2024, pursuant to Executive Order (E.O) 13224, sanctioned eight individuals and eight entities that have been added to OFAC’s sanctions list.

The US Treasury Department’s Office of Foreign Assets Control (OFAC) imposed sanctions on 16 entities and individuals that comprise an extensive business network spanning the Horn of Africa, the United Arab Emirates (UAE) and Cyprus that raises and launders funds for al-Shabaab, an al-Qaeda affiliated terrorist group. Members of this network include influential businessmen in the region who provide financial support to al-Shabaab, the terrorist group responsible for some of the worst terrorist attacks in modern East African history. These attacks have claimed the lives of thousands of innocent civilians.

  • On 12 March 2024, by Executive Order (E.O) 13224, designated the Al-Ashtar Brigades as a Foreign Terrorist Organisation and Specially Designated Global Terrorist in 2018.

The US Treasury Department’s Office of Foreign Assets Control (OFAC) is taking action in coordination with the Kingdom of Bahrain against key Iran-based operatives and a financial facilitator of the designated terrorist group Al-Ashtar Brigades.

  • On March 26, 2024, Executive Order (E.O) 13224 sanctioned six entities, one individual, and two vessels that have been added to OFAC’s sanctioned list.

The Treasury Department’s Office of Foreign Assets Control (OFAC) is sanctioning six entities, one individual, and two tankers based in or registered in Liberia, India, Vietnam, Lebanon, and Kuwait that have been involved in facilitating shipments of goods and financial transactions for the Islamic Revolutionary Guards Corps-Qods Force (IRGC-QF), the Houthis, and Hezbollah.

  • On 26 March 2024, Executive Order (E.O) 13582 sanctioned 11 entities and individuals who have been added to OFAC’s sanctioned list.

The Treasury Department’s Office of Foreign Assets Control (OFAC) sanctioned 11 individuals and entities that support the regime of Syrian President Bashar Al-Assad by facilitating illicit financial transfers and illegal drug trafficking, as well as the extraction and export of Syrian commodities.

ZIMBABWE

  • On 4 March 2024, pursuant to Executive Order (E.O) 13818, eleven individuals and three entities have been added to OFAC’s sanctioned list.

The Treasury Department’s Office of Foreign Assets Control (OFAC) designated 11 individuals, including Zimbabwean President Emmerson Mnangagwa, and three entities for involvement in corruption or serious human rights violations under EO 13818, which implements and enforces the Magnitsky Global Human Rights Accountability Act.

IRAN

  • On 6 March 2024, by Executive Order (E.O) 13224, it extended sanctions against two shipowners and vessels in Hong Kong and the Marshall Islands.

The Treasury Department’s Office of Foreign Assets Control (OFAC) took additional action against shipments of Iranian goods by the network of Iran-based Houthi financial facilitator Sa’id al-Jamal, who is backed by the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF). The action targets two shipowners and two vessels based in Hong Kong and the Marshall Islands for their involvement in the transport of goods on behalf of al-Jamal, and follows a 27 February action targeting a related vessel, the ARTURA.

  • On 15 March 2024, by Executive Order (E.O) 13224, extended sanctions against a Marshall Islands shipping company.

The Treasury Department’s Office of Foreign Assets Control (OFAC) has taken action against the Marshall Islands-registered shipping company Vishnu Inc., whose vessel, the LADY SOFIA, is implicated in illicit shipments to the People’s Republic of China (PRC) in support of the Iranian Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) and US counterterrorism sanctioned financial facilitator Houthi Sa’id al-Jamal.

  • On 20 March 2024, Executive Order (E.O) 13224 sanctioned three procurement networks for missile programmes.

The US Treasury Department’s Office of Foreign Assets Control (OFAC) targeted three procurement networks – based in Iran, Turkey, Oman and Germany – that have supported Iran’s ballistic missile, nuclear and defence programmes.

AFRICA

  • On 8 March 2024, by virtue of Executive Order (E.O) 14024, sanctioned two entities that have been added to OFAC’s sanctioned list.

The Treasury Department’s Office of Foreign Assets Control (OFAC) sanctioned two companies – one in Russia and one in the Central African Republic (CAR) – for their efforts in furthering Russia’s malign activities in CAR. The targets have played an important role in enabling the Private Military Enterprise “Wagner” (Wagner Group) and, by extension, the activities of the Russian Federation

BOSNIA AND HERZEGOVINA

  • On 13 March 2024, by virtue of Executive Order (E.O) 13304, sanctioned three individuals who have been added to OFAC’s sanctioned list.

The US Treasury Department’s Office of Foreign Assets Control (OFAC) has designated three individuals who have contributed to the efforts of Milorad Dodik (Dodik), Specially Designated National (SDN) and President of Republika Srpska (RS), to undermine peace and stability in Bosnia and Herzegovina (BiH).

RUSSIA

  • On 14 March 2024, by virtue of Executive Order (E.O) 14024, four individuals and two entities were added to OFAC’s sanctioned list, and the data of four already sanctioned individuals were amended.
  • On 20 March 2024, pursuant to Executive Order (E.O) 14024, two individuals and two entities were sanctioned and have been added to OFAC’s sanctioned list.
  • On 25 March 2024, pursuant to Executive Order (E.O) 14024 and Executive Order (E.O) 14024, four individuals and nineteen entities have been added to OFAC’s sanctioned list.

NICARAGUA

  • On 21 March 2024, by virtue of Executive Order (E.O) 13851, sanctioned the Attorney General of Nicaragua.

The Treasury Department’s Office of Foreign Assets Control (OFAC) sanctioned Wendy Carolina Morales Urbina, Attorney General of Nicaragua, for being complicit in the oppression of the Ortega-Murillo regime.

NARCOTRAPHIC

  • On 22 March 2024, pursuant to Executive Order (E.O) 14059, sanctioned 15 members of the Sinaloa cartel.

Deputy Treasury Secretary Wally Adeyemo announced, along with Arizona local leaders and law enforcement, that the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) sanctioned the operators of a Black Market Peso Exchange (BMPE) scheme to launder millions in illicit fentanyl proceeds for the Sinaloa Cartel. OFAC designated 15 members of the Sinaloa Cartel – several of whom are fugitives – and six Mexico-based companies under Executive Order 14059.

 

III. UNITED KINGDOM

On 5 March 2024 the UK Government, under the Regime: Russia (Sanctions) (Eu Exit) Regulations 2019 (Regime: Russia (Sanctions) (EU Exit) Regulations 2019) has made 1 administrative amendment under the Russia sanctions regime to the UK Sanctions list.

On 11 March 2024 the UK Government under the Regime: Democratic People’s Republic of Korea (Sanctions) (Eu Exit) Regulations 2019 has made 1 administrative amendment under the Democratic People’s Republic of Korea Sanctions Regime to the UK Sanctions list.

On 25 March 2024 the UK Government, under the Regime: Cyber (Sanctions) (Eu Exit) Regulations 2019, has made 3 further deletions under the Cyber Sanctions Regime to the UK Sanctions list.

 

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In Madrid, 31 March 2024

International Trade and Sanctions Department

Lupicinio International Law Firm

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