Sanctions Watch Vol 69
In the latest edition of our Sanctions Watch weekly digest, we present significant updates on sanction watchlists and regulatory developments.
1. New Task Force Established To Enhance The Effectiveness Of UK Sanctions On Russia
The UK government has launched the Office of Trade Sanctions Implementation (OTSI) to help businesses comply with the country’s trade sanctions against Russia, strengthening enforcement efforts. OTSI will offer guidance, issue licenses, and investigate breaches, focusing on ensuring compliance with the sanctions, which have deprived Russia of over $400 billion since February 2022. The UK’s sanctions, imposed in response to Russia’s invasion of Ukraine, target over £20 billion worth of trade with Russia.
OTSI’s enhanced powers include imposing civil penalties on businesses that fail to comply and publishing details of sanctions breaches. The new unit will also require financial services firms, money service businesses, and legal providers to report suspected breaches. By collaborating with businesses, OTSI aims to ensure maximum pressure on Russia while maintaining strong enforcement of trade sanctions, complementing the existing customs enforcement role of HMRC. The new measures underscore the UK’s commitment to defunding Putin’s regime.
2. EU Establishes New Sanctions Framework Targeting Russian Hybrid Activities
On 8 October, the EU introduced a new sanctions regime in response to Russia’s destabilizing activities. The sanctions target Russian hybrid operations that threaten the EU, its Member States, and international partners. Sweden played a key role in pushing for this action, with Foreign Affairs Minister Maria Malmer Stenergard emphasizing that the sanctions are aimed at individuals and entities responsible for or benefiting from Russian hybrid activities. These activities, which have intensified recently, include sabotage, disinformation, cyberattacks, and the manipulation of migration.
The EU has developed tools within its Strategic Compass for Security and Defence to identify and address such hybrid threats, continuously updating its measures to strengthen resilience. The new sanctions are part of broader efforts to prevent, deter, and respond to Russian aggression by using all available instruments, ensuring that the EU remains robust in countering these complex threats.
3. UK Imposes Sanctions On Russian Forces For Chemical Weapons Use In Ukraine
The UK imposed new sanctions on Russian troops, accusing them of using chemical weapons in Ukraine. Among those sanctioned are the Radiological, Chemical, and Biological Defence Troops of the Russian Federation and their leader, Igor Kirillov. UK Foreign Minister David Lammy condemned Russia’s “cruel and inhumane tactics” and emphasized the country’s commitment to upholding international law, including the Chemical Weapons Convention. Moscow’s embassy in London, however, denied the allegations, calling them baseless.
These sanctions follow the UK’s recent targeting of 16 members of the Russian cyber-crime group Evil Corp, which was reportedly tasked with conducting operations against NATO allies. The move signals Britain’s continued stance against Russia’s actions in Ukraine and its broader efforts to challenge cyber-crime and violations of international law.
4. OFAC Issues General Licenses For Temporary Transactions With Blocked Entities
General License No. 30 and General License No. 31, issued under the Global Terrorism Sanctions Regulations (GTSR), provide temporary authorizations for the wind down of specific transactions involving blocked entities.
General License No. 30 allows for the wind down of transactions involving entities blocked on October 7, 2024, under the Global Terrorism Sanctions Regulations (GTSR). Entities affected include Al Ahmar Trading Group, Al Salam Trading, Sabaturk Dis Ticaret, Vivid Enerji, and Investrade Portfoy. Transactions must be completed by 12:01 a.m. EST on November 21, 2024, with payments directed to blocked accounts. The license does not cover dealings with other blocked entities unless separately authorized.
General License No. 31 authorizes transactions related to debt, equity, or derivative contracts involving Investrade Portfoy Yonetimi Anonim Sirketi and entities where it has 50% or more ownership. These transactions, including divestment, transfer, and trade settlement, are permitted through November 21, 2024. It also covers winding down derivative contracts tied to these entities. U.S. persons are prohibited from facilitating sales or investments to other blocked persons, except for permitted divestments. Payments must be made to blocked accounts.
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Sanctions Watch is a weekly recap of events and news related to sanctions around the world.
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