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, stopping 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.




  • On 12 September 2022, COUNCIL IMPLEMENTING DECISION (CFSP) 2022/1509 of 9 September 2022 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.






  • As of 8 September 2022, one (1) natural person and (4) entities have been added to the SDN list.

The US Treasury Department’s OFAC is designating an air transportation service provider for its involvement in the shipment of Iranian unmanned aerial vehicles (UAVs) to Russia for its war against Ukraine. In addition, OFAC is designating three companies and one individual involved in the research, development, production, and procurement of Iranian UAVs and UAV components, including the Shahed series of unmanned aircraft, for Iran’s Islamic Revolutionary Guard Corps (IRGC) and its Aerospace Force (IRGC ASF) and Navy.

  • As of 9 September 2022, one (1) natural person and one (1) entity have been added to the SDN list.

OFAC has designated Iran’s Ministry of Intelligence and Security (MOIS) and its Minister of Intelligence for engaging in cyber activities against the United States and its allies. Since at least 2007, MOIS and its cyber proxies have conducted malicious cyber operations targeting a range of government and private sector organisations around the world and in various critical infrastructure sectors. In July 2022, cyber threat actors believed to be sponsored by the Government of Iran and MOIS disrupted Albanian government computer systems, forcing the government to suspend online public services for its citizens.

  • As of 22 September 2022, six (6) natural persons and one (1) entity have been added to the SDN list.

The US Treasury Department’s Office of Foreign Assets Control (OFAC) is designating Iran’s Morality Police for abuse and violence against Iranian women and violation of the rights of peaceful Iranian protesters. The Morality Police are responsible for the recent death of 22-year-old Mahsa Amini, who was arrested and imprisoned for allegedly wearing a hijab improperly.

OFAC is also targeting seven senior leaders of Iran’s security organisations: the Morality Police, the Ministry of Intelligence and Security (MOIS), the Army Ground Forces, the Basij Resistance Forces and the Security Forces. These officials oversee organisations that routinely use violence to repress peaceful demonstrators and members of Iranian civil society, political dissidents, women’s rights activists and members of the Iranian Bahá’í community.


  • On 15 September 2022 , pursuant to 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, twenty-two (22) natural persons and two (2) entities have been added to the SDN list.

The US Treasury Department’s Office of Foreign Assets Control (OFAC) has designated 22 individuals and 2 entities, including several individuals who have furthered the objectives of the Government of the Russian Federation in Ukraine, both before and during Russia’s new invasion of Ukraine in 2022. The individuals designated also include the Rusich Operative Group, a neo-Nazi paramilitary group that has engaged in fighting alongside the Russian military in Ukraine, as well as two of its senior leaders.


  • On September 15, 2022, by virtue of Executive Order (E.O.) 13469, one (1) natural person has been added to the SDN list and 11 natural persons have been removed from the SDN list.

The Zimbabwe sanctions program targets those who violate human rights and those who undermine democratic processes or facilitate corruption. The U.S. sanctions do not target the Zimbabwean people, the country, or the Zimbabwean banking sector. The 11 individuals who have been removed from the SDN list are either deceased or have been deemed to no longer undermine Zimbabwe’s democratic processes and institutions. Each year, the U.S. Government removes hundreds of individuals and entities from the SDN List. Each removal is based on a thorough review.


  • Effective September 14, 2022, OFAC has added ten (10) natural persons and two (2) entities to the SDN List for being responsible for or complicit in, or having participated, directly or indirectly, in cyber activities originating from or directed by persons located, in whole or in substantial part, outside the United States, that are reasonably likely to result in, or have materially contributed to, a significant threat to the national security, national security, foreign policy, economic health, or financial stability of the United States and that have the purpose or effect of causing significant misappropriation of funds or economic resources, trade secrets, personal identifiers, or financial information for commercial or competitive advantage or private financial gain.

OFAC has sanctioned these individuals and entities for their involvement in malicious cyber acts, including ransomware activity. The designations are part of a joint action with the Department of Justice, Department of State, Federal Bureau of Investigation, U.S. Cyber Command, National Security Agency, and the Cybersecurity and Infrastructure Security Agency. The designated individuals and entities are all affiliated with the IRGC.



In Madrid, on September 30, 2022

International Trade and Sanctions Department

Lupicinio International Law Firm


International Sanctions, Arbitration, Litigation, Criminal, Competition AND MORE!


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