International sanctions have become a very popular instrument of foreign policy. Once limited to a few cases, they now have a broad mandate. In principle, sanctions aimed at addressing gross violations of human rights, stopping arms sales to parties to armed conflicts and supporting peace negotiations are an important political tool. 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 record 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
RUSSIA
- On 6 October 2022, COUNCIL DECISION (CFSP) 2022/1907 of 6 October 2022 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine has been published in the Official Journal of the European Union.
In view of the gravity of the situation, the Council considers that thirty persons and seven entities responsible for actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine should be added to the list of persons, entities and bodies subject to restrictive measures set out in the annex to Decision 2014/145/CFSP.
- On 6 October 2022, COUNCIL DECISION (CFSP) 2022/1908 of 6 October 2022 amending Decision (CFSP) 2022/266 concerning restrictive measures in response to the recognition of the areas of the non-government-controlled provinces of Donetsk and Luhansk in Ukraine and the order of entry of Russian armed forces into those areas was published in the Official Journal of the European Union.
In view of these serious circumstances, the Council considers that the title of Decision (CFSP) 2022/266 should be amended and the geographical scope of the restrictions it contains should be extended to cover all non-government-controlled areas of Ukraine in Donetsk, Kherson, Luhansk and Zaporiyia oblasts.
- On 6 October 2022, COUNCIL DECISION (CFSP) 2022/1909 of 6 October amending Decision 2014/512/CFSP concerning restrictive measures in view of actions by Russia which destabilise the situation in Ukraine was published in the Official Journal of the European Union.
In view of the seriousness of the situation, it is appropriate to introduce new restrictive measures.
- On 20 October 2022, COUNCIL DECISION (CFSP) 2022/1986 of 6 October 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.
The Iranian regime provides military support to Russia’s unprovoked and unjustified war of aggression against Ukraine. In view of the gravity of the situation, the Council considers that three persons and one entity involved in the development and delivery of UAVs to Russia should be added to the list of persons, entities and bodies subject to restrictive measures set out in the Annex to Decision 2014/145/CFSP.
YEMEN
- On 6 October 2022, COUNCIL IMPLEMENTING DECISION (CFSP) 2022/1902 of 6 October 2022 implementing Decision 2014/932/CFSP concerning restrictive measures in view of the situation in Yemen has been published in the Official Journal of the European Union.
- On 24 October 2022, COUNCIL IMPLEMENTING DECISION (CFSP) 2022/2035 of 6 October 2022 implementing Decision 2014/932/CFSP concerning restrictive measures in view of the situation in Yemen was published in the Official Journal of the European Union.
NICARAGUA
- On 14 October 2022, COUNCIL DECISION (CFSP) 2022/1943 of 13 October 2022 amending Decision (CFSP) 2019/1720 concerning restrictive measures in view of the situation in Nicaragua was published in the Official Journal of the European Union.
CHEMICAL WEAPONS
- On 14 October 2022, COUNCIL DECISION (CFSP) 2022/1944 of 13 October 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..
IRAN
- COUNCIL ENFORCEMENT DECISION (CFSP) 2022/1956 of 17 October 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 17 October 2022.
DAESH AND AL-QAIDA
- On 18 October 2022, COUNCIL DECISION (CFSP) 2022/1967 of 17 October 2022 amending Decision (CFSP) 2016/1693 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.
2. UNITED STATES
BOSNIA-HERZEGOVINA
- On 3 October 2022, OFAC, pursuant to EXECUTIVE ORDER (EO) 14022, which targets persons contributing to the destabilisation of the situation in the Western Balkans, has added two (2) individuals and one (1) entity to the SDN list.
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has designated two individuals and one business entity in Bosnia and Herzegovina (BiH) pursuant to EXECUTIVE ORDER (EO) 14033. These designations follow OFAC’s designation on 26 September 2022 of a corrupt prosecutor in BiH and build on other recent sanctions imposed on individuals and entities in the region. Taken together, these actions underscore the United States’ willingness to hold accountable those who enable divisive and destabilising activities in the Western Balkans..
“Today’s action underscores how politicians in Bosnia and Herzegovina are undermining democratic institutions and processes for their own political gain and to reward their patronage networks,” said Treasury Under Secretary for Terrorism and Financial Intelligence Brian E. Nelson. “We will continue to pursue those who destabilise the region, as well as those who support them, and hold them accountable.”
As set out in the 1995 Dayton Peace Agreement (DPA), which includes the current BiH constitution and remains the basis for BiH’s governance structure, BiH consists of two entities: the Federation of Bosnia and Herzegovina (FBiH) and the Republika Srpska (RS).
IRAN
- On 6 October 2022, OFAC, pursuant to EXECUTIVE ORDER (EO) 13553, which authorises the imposition of sanctions for serious human rights violations by the Government of Iran, and pursuant to EXECUTIVE ORDER (EO) 13846, which authorises the imposition of sanctions for engaging in censorship or other activities with respect to Iran, has added seven (7) individuals and one (1) entity to the SDN List.
The US Treasury Department’s Office of Foreign Assets Control (OFAC) has designated seven senior leaders of Iran’s government and security apparatus for shutting down internet access in Iran and for continued violence against peaceful protesters following the tragic death of 22-year-old Mahsa Amini, who was arrested for allegedly wearing a hijab improperly and died in the custody of Iran’s Morality Police. Today’s action follows OFAC’s designation on 22 September of the Iranian Morality Police, its senior leadership and other senior leaders of Iran’s security organisations. Together with the issuance of Iran’s D-2 General License, which authorises the export of additional tools to help Iranians access the internet, these designations demonstrate the US commitment to freedom of peaceful assembly and open communication.
“The rights to free speech and peaceful assembly are vital to ensuring the liberty and dignity of individuals,” said Treasury Undersecretary Brian Nelson. “The United States condemns the Iranian government’s shutdown of the internet and continued violent suppression of peaceful protests and will not hesitate to prosecute those who direct and support these actions.”
NORTH KOREA
- On October 7, 2022, OFAC, pursuant to EXECUTIVE ORDER (EO) 13810 imposing sanctions against North Korea, and pursuant to EXECUTIVE ORDER (EO) 13581, imposing a freeze on the assets of transnational criminal organizations, added three (3) individuals and five (5) entities to the list of those individuals and entities..
The US Treasury Department’s Office of Foreign Assets Control (OFAC) designated two individuals and three entities for activities related to the export of oil to the Democratic People’s Republic of Korea (DPRK), which directly supports the development of the DPRK’s weapons programmes and its military. This action underscores the U.S. Government’s commitment to implement existing United Nations Security Council Resolutions (UNSCRs), including holding the DPRK accountable for its use of illicit ship-to-ship (STS) transfers to circumvent UN sanctions that restrict the import of petroleum products and support the development of its weapons programmes and military.
“The DPRK’s long-range ballistic missile launches, including over Japan, demonstrate continued disregard for United Nations Security Council resolutions,” said Brian Nelson, Under Secretary for Terrorism and Financial Intelligence. “The United States will continue to enforce multilateral sanctions and pursue DPRK sanctions evasion efforts around the world, including designating those who support these activities.”
The US Treasury Department’s Office of Foreign Assets Control (OFAC) designated Malaysian national Teo Boon Ching, Malaysian wildlife trafficking Transnational Criminal Organisation (TCO) Teo Boon Ching and Malaysian company Sunrise Greenland Sdn. Bhd. for the cruel trafficking of endangered and threatened wildlife and the products of brutal poaching. Teo Boon Ching specialises in transporting rhino horn, ivory and pangolins from Africa, usually using routes through Malaysia and Laos to reach consumers in Vietnam and China.
“Wildlife trafficking groups are cruel and inhumane, and they perpetuate corruption and illicit finance,” said Treasury Under Secretary for Terrorism and Financial Intelligence Brian E. Nelson. “The United States views wildlife trafficking not only as a critical conservation problem, but also as a threat to global security.”
Today’s action is the result of collaboration between the U.S. Department of the Treasury, the U.S. Fish and Wildlife Service, the U.S. Department of State, and the U.S. Department of Justice. The United States appreciates the assistance of the Royal Thai Government in this case.
TERRORISM
- On October 17, 2022, OFAC, pursuant to EXECUTIVE ORDER (EO) 13224, which seeks to block the ownership of and prohibit transactions with persons who commit, threaten to commit, or support terrorism, has added fourteen (14) individuals to the SDN List.
RUSSIA
- On 19 October 2022, OFAC, pursuant to EXECUTIVE ORDER (EO) 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, added one (1) individual and two (2) entities to the SDN list.
In coordination with the US Department of Justice and the Federal Bureau of Investigation (FBI), the Treasury Department’s Office of Foreign Assets Control (OFAC) has designated a Russian network that procured sensitive dual-use and military technologies from US manufacturers and supplied them to Russian end-users.
Today’s designees are Russian national and procurement agent Yury Yuryevich Orekhov (Orekhov) and two of his companies, Nord-Deutsche Industrieanlagenbau GmbH (NDA GmbH) and Opus Energy Trading LLC (Opus Energy Trading). Today’s designations highlight the US government’s continued efforts to hinder Russia’s ability to wage its war of aggression in Ukraine, including by holding those who support the Russian military accountable by disrupting their illicit defence and technology procurement networks around the world.
Today’s action builds on last week’s meeting of senior officials representing finance ministries and other government agencies from 33 countries to discuss the effects of international sanctions and export controls on Russia’s military-industrial complex and critical defence supply chains. The Treasury, Commerce and State Departments on Friday issued an alert detailing the impact of international sanctions and export controls.
NARCOTICS
- On 19 October 2022, OFAC, pursuant to EXECUTIVE ORDER (EO) 14059 imposing sanctions on foreign persons involved in the global illicit drug trade, has added three (3) individuals and four (4) entities to the SDN List.
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated Juan Francisco Valenzuela Valenzuela and the Valenzuela Drug Trafficking Organization (“Valenzuela DTO”), among others, pursuant to EXECUTIVE ORDER (EO) 14059.
Originally established as a transportation cell, the Valenzuela OTD evolved into a sophisticated network that became invaluable to the Sinaloa Cartel’s leadership. The Valenzuela DTO, named after the family that facilitated its rise to fame, was run by brothers Jorge Alberto, Wuendi Yuridia and Juan Francisco Valenzuela Valenzuela Valenzuela in recent years. Following the arrests of Jorge Alberto and Wuendi Yuridia by US authorities in October 2020 and November 2021, respectively, Juan Francisco Valenzuela Valenzuela is the last remaining brother involved in OTD Valenzuela’s operations in Mexico. Operating under the umbrella of the Sinaloa Cartel, DTO Valenzuela is involved in importing and transporting multi-ton quantities of illicit drugs, including methamphetamine, heroin and fentanyl, from Mexico to the United States.
“The Valenzuela drug trafficking organisation fuels the ongoing drug epidemic we face in the United States that has resulted in the deaths of tens of thousands of Americans each year,” said Treasury Under Secretary for Terrorism and Financial Intelligence Brian E. Nelson. “Depriving this network of resources will help deprive the Sinaloa Cartel of the critical support it needs to traffic its dangerous illicit drugs.”
3. UNITED KINGDOM
RUSSIA
- On 4 October 2022 the UK Government, under the Regime: Russia (Sanctions) (Eu Exit) Regulations 2019, added one (1) individual to the UK Sanctions List (“UKSL List”).
YEMEN
- On 5 October 2022 the UK Government, pursuant to the Regime: Yemen (Sanctions) (Eu Exit) Regulations 2020 has added one (1) individual to the UK Sanctions List (‘UKSL List’).
IRAN
- On 10 October 2022 the UK Government has added eight (8) individuals to the UK Sanctions List (“UKSL List”) under the Iran (Human Rights) (EU Exit) Regulations 2019.
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In Madrid, 31 October 2022
International Trade and Sanctions Department
