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 achieving 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. Their abusive use has led to an increase in their negative side-effects.
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 it affects not only the sanctioned countries and individuals, but also those who do business with them in some way.
I. EUROPEAN UNION
- On 22 May 2023, Council ENFORCEMENT DECISION (CFSP) 2023/987 of 22 May 2023 implementing Decision 2011/235/CFSP concerning restrictive measures directed against certain persons and entities in view of the situation in Iran has been published in the Official Journal of the European Union.
The Council decided to add five individuals and two entities to the list of natural and legal persons subject to restrictive measures. The five natural persons and two entities have been included because of their alleged involvement in human rights violations in the context of the protests against the Iranian regime.
- COUNCIL DECISION (CFSP) 2023/964 amending Decision (CFSP) 2019/797 concerning restrictive measures against cyber attacks against the Union or its Member States was published in the Official Journal of the European Union on 15 May 2023.
Article 10 of Decision (CFSP) 2019/797 shall be replaced by the following: “This Decision shall apply until 18 May 2025 and shall be subject to continuous review. The measures set out in Articles 4 and 5 shall apply until 18 May 2024 to the natural and legal persons, entities and bodies listed in the Annex”.
II. UNITED STATES
- On 19 May 2023, 22 individuals and 104 entities associated with 20 jurisdictions were designated under Executive Order (E.O.) 14024.
The United States, in coordination with the G7 and other international partners, is strengthening unprecedented global sanctions and other restrictive economic measures in an attempt to further degrade the Russian Federation’s ability to.
The sanctions imposed by OFAC on 22 individuals and 104 entities, with points of contact in more than 20 countries or jurisdictions, target those seeking to evade or circumvent sanctions and other economic measures against Russia, the channels Russia uses to acquire critical technology, its future energy extraction capabilities, and Russia’s financial services sector.
In addition, OFAC is expanding sanctions authorities to target new sectors of the Russian economy and cut off Russia’s access to new categories of services. The US State Department also designated or identified nearly 200 individuals, entities, vessels and aircraft as blocked goods. The US Department of Commerce is expanding the territorial scope and categories covered by its export control, adding 71 entities to its List to prevent Russia from accessing goods it needs for the battlefield.
- As of 9 May 2023, pursuant to Executive Order (E.O) 14059, seven individuals and two entities have been sanctioned.
The US Treasury Department’s Office of Foreign Assets Control (OFAC) has sanctioned Joaquín Guzmán López, the son of Joaquín “El Chapo” Guzmán Loerea, and four members of Los Chapitos, as well as three members of the Sinaloa Cartel and two Mexican entities based in Mexico. These sanctioned individuals are part of the Sinaloa Cartel network overseen by Los Chapitos and responsible for a significant portion of the illegal fentanyl and other drugs trafficked into the United States.
“Treasury, in close coordination with the Government of Mexico and U.S. law enforcement, will continue to seize opportunities to isolate and disrupt the operations of Los Chapitos and the Sinaloa Cartel at every juncture,” said Treasury Under Secretary for Terrorism and Financial Intelligence Brian Nelson.
- On 2 May 2023 OFAC, by virtue of Executive Order (E.O.) , 13224, two entities have been designated.
The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC), in a joint action with the authorities of the Republic of Turkey, designated two financial facilitators of the Syria-based terrorist groups Hay’at Tahrir al-Sham (HTS) and Katibat al-Tawhid wal-Jihad (KTJ), both sanctioned by the United States and the United Nations.
“As terrorist groups continue to seek access to the international financial system, working with our partners enhances our ability to more effectively disrupt these facilitation networks,” said Treasury Under Secretary for Terrorism and Financial Intelligence Brian E. Nelson. “Treasury remains committed to working with Türkiye and others in the region to disrupt the flow of funds to terrorist groups and degrade their ability to operate.”
- On 16 May 2023 OFAC, pursuant to Executive Order (E.O.) , 13694 as amended by Executive Order (E.O.) , an individual has been designated.
The US Treasury Department’s Office of Foreign Assets Control (OFAC) has sanctioned Mikhail Matveev (Matveev) for his involvement in launching cyberattacks against law enforcement, businesses and critical infrastructure.
At the same time, the District Courts of New Jersey and the District of Columbia filed indictments against Matveev. In addition, the US State Department announced a reward of up to $10 million for information leading to Matveev’s arrest and/or conviction under its Transnational Organised Crime Reward Programme.
The consequences of ransomware attacks are enormous, with victims suffering the loss and disclosure of sensitive information and the disruption of critical services. Russia is a haven for ransomware authors, allowing cybercriminals like Matveev to engage in ransomware attacks against US organisations.
- The Treasury Department’s Office of Foreign Assets Control (OFAC) is amending the South Sudan Sanctions Regulations and republishing them in their entirety. This regulatory amendment became effective upon publication in the Federal Register on 18 May 2023.
III. UNITED KINGDOM
- On 19 May 2023 the UK Government, under the Regime: Russia (Sanctions) (Eu Exit) Regulations 2019, added 86 new designations and three revocations under the Russia sanctions regime to the UK Sanctions list..
In Madrid, 31 May 2023
International Trade and Sanctions Department