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, halting 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
MYANMAR
- On 8 November 2022, Council DECISION (CFSP) 2022/21878 of 8 November 2022 amending Decision 2013/184/CFSP concerning restrictive measures in view of the situation in Myanmar/Burma was published in the Official Journal of the European Union.
In view of the continuing serious situation in Myanmar/Burma, 19 persons and one entity should be added to the list of natural and legal persons, entities and bodies subject to restrictive measures as set out in the Annex to Decision 2013/184/CFSP.
TURKEY
- COUNCIL DECISION (CFSP) 2022/2186 of 8 November 2022 amending Decision (CFSP) 2019/1894 concerning restrictive measures in view of unauthorised Turkish drilling activities in the Eastern Mediterranean has been published in the Official Journal of the European Union on 9 November 2022.
MALI
- On 9 November 2022, COUNCIL IMPLEMENTING DECISION (CFSP) 2022/2187 implementing Decision (CFSP) 2017/1775 concerning restrictive measures in view of the situation in Mali was published in the Official Journal of the European Union.
DEMOCRATIC PEOPLE’S REPUBLIC OF KOREA
- On 9 November 2022, COUNCIL IMPLEMENTING DECISION (CFSP) 2022/2188 of 8 November 2022 implementing Decision (CFSP) 2016/849 concerning restrictive measures against the Democratic People’s Republic of Korea was published in the Official Journal of the European Union.
VENEZUELA
- On 11 November 2022, COUNCIL DECISION (CFSP) 2022/2201 of 10 November 2022 amending Decision (CFSP) 2017/2074 concerning restrictive measures in view of the situation in Venezuela was published in the Official Journal of the European Union.
CHEMICAL WEAPONS
- On 14 November 2022, COUNCIL DECISION (CFSP) 2022/2232 of 14 November 2022 amending Decision (CFSP) 2018/1544 concerning restrictive measures against the proliferation and use of chemical weapons was published in the Official Journal of the European Union.
The Union has strongly condemned Syria’s use of chemical weapons and its failure to comply with its international obligations under the Chemical Weapons Convention, as demonstrated by thorough and rigorous investigations by the UN and the OPCW. The Union has raised these concerns in various fora and urges Syria to return to full compliance with the Chemical Weapons Convention.
RUSSIA
- On 14 November 2022, COUNCIL DECISION (CFSP) 2022/2233 of 14 November 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.
IRAN
- COUNCIL ENFORCEMENT DECISION (CFSP) 2022/2234 of 14 November 2022 implementing Decision 2011/235/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 on 14 November 2022.
- COUNCIL IMPLEMENTING DECISION (CFSP) 2022/2235 of 14 November 2022 implementing Decision 2011/235/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 on 14 November 2022.
On 25 September 2022, the High Representative of the Union for Foreign Affairs and Security Policy issued a statement on behalf of the Union deploring the widespread and disproportionate use of force by Iranian security forces against peaceful demonstrators, resulting in a high number of deaths and injuries. The statement also noted that those responsible for the killing of Mahsa Amini must be held accountable, and urged the Iranian authorities to ensure that transparent and credible investigations are carried out to clarify the number of deaths and arrests, to release all peaceful demonstrators and to ensure due process for all detainees. The statement also stressed that Iran’s decision to severely restrict internet access and block instant messaging platforms blatantly violates freedom of expression. Finally, the statement affirmed that the Union would consider all options at its disposal to address the killing of Mahsa Amini and the manner in which Iranian security forces have responded to the subsequent demonstrations.
DEMOCRATIC REPUBLIC OF CONGO
- On 15 November 2022, COUNCIL DECISION (CFSP) 2022/2241 of 14 November 2022 amending 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.
On 30 June 2022, the United Nations Security Council (UNSC) adopted Resolution 2641 (2022), which amends the criteria for the designation of persons and entities subject to the restrictive measures set out in paragraphs 9 and 11 of UNSC Resolution 1807 (2008), as well as the scope of the obligation to notify the Sanctions Committee, established pursuant to UNSC Resolution 1533 (2004), of shipments of arms and related materiel to the DRC, or any provision of technical assistance, financing or brokering services and other services related to military activities in the DRC.
HAITI
- On 28 November 2022, COUNCIL DECISION (CFSP) 2022/2319 of 25 November 2022 concerning restrictive measures in view of the situation in Haiti was published in the Official Journal of the European Union.
On 21 October 2022, the United Nations Security Council (hereinafter referred to as the ‘Security Council’) adopted Resolution 2653 (2022), in which it reaffirms its firm commitment to the sovereignty, independence, territorial integrity and unity of Haiti.
United Nations Security Council Resolution (hereinafter referred to as ‘UNSCR’) 2653 (2022) recalls all previous Security Council resolutions on Haiti, in particular UNSCR 2645 (2022), in which, inter alia, it called for an immediate cessation of gang violence and criminal activities and expressed the readiness of the Security Council to take as necessary, appropriate measures against those who engage in or support gang violence, criminal activities or human rights abuses, or take any other action that undermines peace, stability and security in Haiti and the region.
Having determined that the situation in Haiti continues to constitute a threat to international peace and security, UNSCR 2653 (2022) requires that travel restrictions be applied to persons designated by the Committee established by its paragraph 19 (hereinafter referred to as the ‘Sanctions Committee’), that all funds and economic resources of persons or entities designated by the Sanctions Committee be frozen, and that an arms embargo be applied to persons or entities designated by the Sanctions Committee.
2. UNITED STATES
TERRORISM
- As of November 3, 2022, OFAC pursuant to Executive Order (E.O.) 13224, which authorizes the imposition of sanctions to prevent the financing of terrorism, fourteen (14) individuals, seventeen (17) entities and eleven (11) vessels have been added to the SDN list.
- As of November 7, 2022, OFAC pursuant to Executive Order (E.O.) 13224, which authorizes the imposition of sanctions to prevent the financing of terrorism, four (4) individuals and eight (8) entities have been added to the SDN list.
- Effective November 30, 2022, OFAC pursuant to Executive Order (E.O.) 13224, authorizing the imposition of sanctions to prevent the financing of terrorism, four (4) individuals have been added to the SDN list.
NARCOTICS
- As of November 4, 2022, OFAC pursuant to Executive Order (E.O.) 14059, which authorizes the imposition of sanctions on aliens involved in global illicit drug trafficking, two (2) individuals have been added to the SDN List.
- As of 17 November 2022, OFAC pursuant to Executive Order (E.O.) 14059, which authorises the imposition of sanctions on aliens involved in global illicit drug trafficking, two (2) individuals and one (1) entity have been added to the SDN List.
CYBERDELINQUENCY and NORTH KOREA
- On 7 November 2022, OFAC pursuant to Executive Orders (E.O.) 13694 and 13722, limiting the proliferation of malicious cyber activity, blocking North Korean Government property and prohibiting certain transactions with respect to North Korea, respectively, two (2) individuals and one (1) entity have been added to the SDN list.
MYANMAR
- As of 7 November 2022, OFAC by virtue of Executive Order (E.O.) 14014, blocking property with respect to the situation in Burma, one (1) individual and one (1) entity have been added to the SDN list.
NARCOTICS and TERRORISM
- As of 9 November 2022, OFAC pursuant to Executive Orders (E.O.) 13224 and 14059, authorising the imposition of sanctions to prevent the financing of terrorism, and authorising the imposition of sanctions on foreign nationals involved in global illicit drug trafficking respectively, five (5) individuals and nine (9) entities have been added to the SDN List.
RUSIA
- As of 14 November 2022, OFAC 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, has added fourteen (14) individuals, twenty-eight (28) entities and eight (8) aircraft to the SDN list.
- As of 15 November 2022, OFAC 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, two (2) individuals and two (2) entities have been added to the SDN list.
IRAN
- As of 16 November 2022, OFAC Executive Order (E.O.) 13846, re-imposing certain sanctions with respect to Iran, has added six (6) individuals to the SDN list.
- As of 17 November 2022, OFAC Executive Order (E.O.) 13846, re-imposing certain sanctions with respect to Iran, has added eight (8) entities to the SDN list.
- On 19 November 2022, OFAC Executive Order (E.O.) 13846, reimposing certain sanctions with respect to Iran, added three (3) individuals to the SDN list.
3. UNITED KINGDOM
RUSSIA
- On 2 November 2022, the UK Government, under the Regime: Russia (Sanctions) (Eu Exit) Regulations 2019, added four (4) individuals to the UK Sanctions List (“UKSL List”).
- On 30 November 2022, the UK Government, under the Regime: Russia (Sanctions) (Eu Exit) Regulations 2019, added twenty-two (22) individuals to the UK Sanctions List (“UKSL List”).
IRAN
- On 14 November 2022 the UK Government, pursuant to the Regime: (Sanctions) (Human Rights) (EU Exit) Regulations 2019 to provide for the freezing of funds and economic resources of certain persons, entities or bodies implicated in the commission of serious human rights violations or abuses in Iran, has added to the UK Sanctions List (“UKSL List”) twenty-four (24) persons.
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In Madrid, 30 November 2022
International Trade and Sanctions Department
