INTERNATIONAL SANCTIONS NOVEMBER 2023

2023-11-30 International Sanctions Newsletters

I. UNITED STATES (OFAC)

RUSSIA
Suppliers of military equipment and technology

As of 2 November 2023, OFAC has sanctioned 130 Russian individuals and companies.

The US Treasury Department’s Office of Foreign Assets Control (OFAC) continues to disrupt the networks and channels through which Russia attempts to sustain its beleaguered military. Today’s sanctions target individuals and entities instigating Russia’s ruthless war against Ukraine by providing Russia with much-needed technology and equipment from third countries. In addition, these actions target Russia’s domestic industrial base, which is attempting to reinvent itself as the maintainer of Russia’s war machine. With these designations, the Treasury is disrupting producers, exporters and importers of nearly every high-priority item identified by the international coalition imposing sanctions and export controls on Russia.

Unable to produce domestically much of the technology, equipment and other materials it needs to sustain and maintain its military-industrial complex, Russia has offshored that production, turning to third-country suppliers to procure the goods it needs. Russia continues to exploit otherwise legitimate economic relations with the People’s Republic of China (PRC), Turkey and the United Arab Emirates (UAE), which have become hubs for exporting, re-exporting and trans-shipping foreign-made technology and equipment to Russia. Treasury continues to work with its partners to prevent further evasion of Russian sanctions and export control violations through their jurisdictions. Recent steps taken, particularly by the UAE, are encouraging, and the US looks forward to working with partners to verify that Russia is no longer able to exploit their jurisdictions.

As of 3 November 2023, OFAC has placed ZHDANOVA, Ekaterina Valeryevna, on the list of designees.

The Treasury Department’s Office of Foreign Assets Control (OFAC) sanctioned Ekaterina Zhdanova, a Russian national, for her role in laundering and moving funds using virtual currency on behalf of Russian elites. This action is consistent with the G7’s commitment to crack down on sanctions evasion and close loopholes that allow the Russian state, its elites, proxies and oligarchs to leverage virtual currency to counter the impact of international sanctions.

As of 16 November 2023, OFAC has listed eight individuals and six entities as designated.

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated eight individuals and six entities pursuant to Executive Order (E.O.) 14033 concerning the Western Balkans and E.O. 14024 concerning Russia. In a coordinated action, the US State Department also designated two individuals and 12 entities under E.O. 14024.
Oil

As of 16 November 2023, OFAC has placed 3 Russian entities and 3 oil pipelines on the sanctioned list.

The US Treasury Department’s Office of Foreign Assets Control (OFAC) imposes sanctions on three entities and identifies as blocked assets three vessels that used Price Cap Coalition service providers while transporting Russian crude oil above the Coalition’s agreed maximum price. This action underscores the Treasury’s commitment, along with its international partners, to responsibly reduce oil revenues that the Russian government can use to finance its brutal invasion of Ukraine.

NARCOTICS
MEXICO

As of 7 November 2023, OFAC has placed 13 individuals and 4 entities on the sanctioned list.

The US Treasury Department’s Office of Foreign Assets Control (OFAC) sanctioned 13 members of the Sinaloa Cartel – several of whom are fugitives – and four entities based in Sonora, Mexico. Responsible for a significant portion of the illicit trafficking of fentanyl and other deadly drugs into the United States, the Sinaloa cartel is one of the most powerful and widespread drug trafficking organisations in the world. This action was closely coordinated with the Mexican government, including the Financial Intelligence Unit (FIU).

COSTA RICA

As of 15 November 2023, OFAC has placed BELL FERNANDEZ, Gilbert Hernan of Los Angeles (a.k.a. “MACHO COCA”) on the sanctioned list.

The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) designated Gilbert Hernan de Los Angeles Bell Fernandez (Bell), a Costa Rican drug trafficker, known not only for the volume of drugs he moves but for the violence with which he operates, who has played a significant role in Costa Rica’s recent transformation into a major narcotics transit hub.

COUNTER-TERRORISM

HAMAS

As of 14 November 2023, OFAC has placed 8 individuals and 2 entities on the sanctions list.

The US Treasury Department’s Office of Foreign Assets Control (OFAC) imposed its third round of sanctions against individuals and entities affiliated with Hamas since the 7 October Hamas terrorist attacks against Israel. This action designates key Hamas officials and the mechanisms through which Iran provides support to Hamas and Palestinian Islamic Jihad (PIJ). Today’s designations are coordinated with actions taken by the United Kingdom and are intended to protect the international financial system from abuses by Hamas and its accomplices. At the same time, the US State Department has designated a leader of the military wing of Palestinian Islamic Jihad.

IRAN

OFAC has placed 6 individuals and 1 entity on the sanctions list as of 17 November 2023.

The US Treasury Department’s Office of Foreign Assets Control (OFAC) has designated six individuals affiliated with the Iran-aligned militia group Kata’ib Hezbollah (KH), based in Iraq. Trained, funded and supported by Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF), KH is behind a series of recent attacks against the United States and its partners in Iraq and Syria in the wake of Hamas’ horrific attacks on Israel. The US State Department has also designated Kata’ib Sayyid al-Shuhada (KSS) and its leader Hashim Finyan Rahim al-Saraji. KSS, another Iraq-based IAMG supported by the IRGC, has planned and participated in attacks against US personnel in Iraq and Syria.

II. EUROPEAN UNION

CENTRAL AFRICAN REPUBLIC

On 10 November 2023, Council Decision (CFSP) 2023/2487 of 9 November 2023 amending Decision 2013/798/CFSP concerning restrictive measures in view of the situation in the Central African Republic was published in the Official Journal of the European Union.

An amendment is made to Article 3 of Regulation (EU) No 224/2014, providing that arms embargo measures and related notification requirements no longer apply to the supply, sale or transfer of arms and related materiel, and to the provision of assistance, advice and training to the security forces of the Central African Republic, including the civilian law enforcement institutions of the State.

TURKEY

On 10 November 2023, Council Regulation (EU) 2023/2507 of 9 November 2023 amending Regulation (EU) 2019/1890 concerning restrictive measures in view of unauthorised Turkish drilling activities in the Eastern Mediterranean was published in the Official Journal of the European Union.
On 10 November 2023, Council Decision (CFSP) 2023/2488 of 9 November 2023 amending Decision (CFSP) 2019/1894 concerning restrictive measures in view of Turkey’s unauthorised drilling activities in the Eastern Mediterranean was published in the Official Journal of the European Union.

The Council extends the measures in Decision (CFSP) 2019/1894 until 30 November 2024.

LIBYA

On 10 November 2023, Council Implementing Regulation (EU) 2023/2501 of 9 November 2023 implementing Regulation (EU) 2016/44 concerning restrictive measures in view of the situation in Libya was published in the Official Journal of the European Union.

The Council considers that the entries for two persons and one entity should be deleted and the restrictive measures against all other persons and entities listed in Annex III to Regulation (EU) 2016/44 should be maintained. In addition, the identifying information concerning one person should be updated.

On 10 November 2023, Council Implementing Regulation (EU) 2023/2504 of 9 November 2023 implementing Regulation (EU) 2016/44 concerning restrictive measures in view of the situation in Libya was published in the Official Journal of the European Union.

Following the judgment of the Court of Justice of the European Union in case C-413/21 P (2), the entry for one person should be deleted.

On 10 November 2023, Council Implementing Decision (CFSP) 2023/2499 of 9 November 2023 implementing Decision (CFSP) 2015/1333 concerning restrictive measures in view of the situation in Libya was published in the Official Journal of the European Union.

The Council considers that the entries for two persons and one entity should be deleted and the restrictive measures against all other persons and entities listed in Annexes II and IV to Decision (CFSP) 2015/1333 should be maintained. In addition, the identifying information concerning one person should be updated.

On 10 November 2023, Council Implementing Decision (CFSP) 2023/2503 of 9 November 2023 implementing Decision (CFSP) 2015/1333 concerning restrictive measures in view of the situation in Libya was published in the Official Journal of the European Union.

Following the judgment of the Court of Justice of the European Union in case C-413/21 P (2), the entry for one person should be deleted.

VENEZUELA

On 13 November 2023, Council implementing regulation (EU) 2023/2500 of 10 November 2023 implementing regulation (EU) 2017/2063 concerning restrictive measures in view of the situation in Venezuela was published in the Official Journal of the European Union.

The Council has reviewed the restrictive measures in force, in accordance with Article 17(4) of Regulation (EU) 2017/2063. In the light of this review, the restrictive measures against all persons on the list, with the exception of one person who is deceased, should be extended until 14 May 2024 and the grounds for listing of sixteen persons should be updated.

On 13 November 2023, Council Decision (CFSP) 2023/2498 of 10 November 2023 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.

The Council has reviewed the restrictive measures in force, in accordance with Article 13 of Decision (CFSP) 2017/2074. In the light of this review and considering the political, economic, social and humanitarian crisis in Venezuela and the persistent actions undermining democracy, the rule of law and respect for human rights, the restrictive measures, including the entire list, with the exception of one person who has died, should be extended until 14 May 2024 and the grounds for listing of sixteen persons should be updated.

HAITI

On 14 November 2023, Council Implementing Regulation (EU) 2023/2573 of 13 November 2023 implementing Regulation (EU) 2022/2309 adopting restrictive measures in view of the situation in Haiti was published in the Official Journal of the European Union.

The Council updated the information concerning one person listed in Annex I to Regulation (EU) 2022/2309.

On 14 November 2023, Council Decision (CFSP) 2023/2575 of 13 November 2023 amending Decision (CFSP) 2022/2319 concerning restrictive measures in view of the situation in Haiti was published in the Official Journal of the European Union.

Decision (CFSP) 2022/2319 should be amended by updating the information concerning one person listed in Annex I to that Decision.

DEMOCRATIC PEOPLE’S REPUBLIC OF KOREA

On 14 November 2023, Council Implementing Regulation (EU) 2023/2576 of 13 November 2023 implementing Regulation (EU) 2017/1509 concerning restrictive measures against the Democratic People’s Republic of Korea was published in the Official Journal of the European Union.

The Council has decided that the restrictive measures against all persons and entities listed in Annexes XV and XVI to Regulation (EU) 2017/1509 should be maintained, with the exception of one deceased person listed in Annex XV to that Regulation, whose entry should be deleted. The entries for 16 persons and four entities listed in those Annexes should be updated. In addition, the entries for 23 persons and one entity listed in Annex XIII should be updated.

On 14 November 2023, Council Decision (CFSP) 2023/2540 of 13 November 2023 amending 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.

The Council has decided that the restrictive measures against all persons and entities listed in Annexes II and III to Decision (CFSP) 2016/849 should be maintained, with the exception of one deceased person listed in Annex II to that Decision, whose entry should be deleted. The entries in the lists for 16 persons and four entities listed in those Annexes should be updated. In addition, the entries in the lists for 23 persons and one entity listed in Annex I should be updated.

EIIL (DAESH) AND AL-QAIDA

On 14 November 2023, Commission Implementing Regulation (EU) 2023/2670 of 22 November 2023 amending for the 339th time Council Regulation (EC) No 881/2002 imposing certain specific restrictive measures directed against certain persons and entities associated with ISIL (Da’esh) and Al-Qaida was published in the Official Journal of the European Union.

The Council amends Annex I to Regulation (EC) No 881/2002 as regards five entries in the list of persons, groups and entities to whom the freezing of funds and economic resources should apply.

III. UNITED KINGDOM

RUSSIA

As of 8 November 2023, OFSI has sanctioned 18 new individuals and 11 entities.

OFSI has designated 18 new individuals and 11 entities on the basis that (i) they have been involved in obtaining a benefit from the Government of Russia by conducting business activities in a sector of strategic importance to the Government of Russia, namely financial services, defence, construction or electronics; or (ii) the entity through which they operate is an entity affiliated with the Government of Russia; or (iii) their actions contribute to destabilising Ukraine or to undermining or threatening the territorial integrity, sovereignty or independence of Ukraine.

As of 9 November, OFSI has removed 1 individual from the Russian sanctioned list.

Sergey STOGNIENKO has been removed from the Consolidated List and is no longer subject to an asset freeze or fiduciary sanctions.

COUNTER-TERRORISM

As of 14 November, OFSI has made 6 new designations to the Counter-Terrorism Sanctions List.

Nabil Khaled Hilal CHOUMAN, Muhammad DEIF, Musa Muhammad Salim DUDIN, Adbelbasit Elhassan Mohamed Khair HAMZA, Marwan ISSA and Yahya Ibrahim Hassan SINWAR have been added to the consolidated list and have been subject to an assets freeze.
IRAN