• The US, UK and EU have all threatened to introduce new sanctions measures on Russia in light of the escalating military tensions between Russia and Ukraine. While details of the proposed new targets are yet to be confirmed, statements by leaders in the US and UK suggest a level of coordination to introduce measures against politically significant oligarchs, major Russian financial institutions and companies operating in strategically important sectors, such as oil and gas.  While legislation on new Russia sanctions is reportedly close to being finalised, it remains to be seen whether it will be introduced should the border tensions alleviate.

• In related actions, the US has sanctioned four individuals, including two serving Ukrainian MPs, for their alleged connection with the Russian security services and involvement in a plot to replace the current elected government in the country.

• The US has sanctioned further individuals under its Global Magnitsky act, which allows the US to target individuals implicated in corruption. In the latest round of sanctions, the US has targeted Bosnian co-President Milorad Dodik and a media outlet under his control.

• The US has also imposed further sanctions on individuals involved in the financing of Hezbollah. On 19^th January three individuals and 10 entities were sanctioned under counter-terrorism sanctions programmes.  The sanctions come at a time when Hezbollah is reportedly blocking the implementation of economic reforms in Lebanon.

• Another target of increased US sanctions pressure is Nicaragua, which is accused by the US of committing acts of violence against civilians. Six further officials were sanctioned ahead of the inauguration of President Daniel Ortega.   The EU also added seven individuals and three entities to its Nicaragua sanctions programme in a move co-ordinated with the US.

• The US has also sanctioned further regime officials and private entities in Myanmar for their affiliation with the country’s military junta, which led a coup d’etat in January 2021. The UK and Canada have included the same individuals and entities in their Burmese sanctions programmes.

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• On 3^rd November 2021 the US Department of Commerce’s Bureau of Industry and Security (“BIS”) added the Israeli information security technology company NSO Group to its entity list, prohibiting US entities from exporting technology to the company or re-exporting technology to it from third parties based elsewhere. The designation was imposed due to NSO Group’s development and distribution of spyware used by authoritarian regimes in repression of civil society and other actors both within their borders and internationally.  Three other technology firms, Candiru (Israel), Positive Technologies (Russia) and Computer Security Initiative Consultancy Pte Ltd (Singapore), were added to the BIS list for the same reason.

• The US has sanctioned the Eritrean Defence Force and the People’s Front for Democracy and Justice (“PFDJ”), led by Eritrean President Isaias Afwerki, further to its introduction of a programme in September 2021 targeting individuals contributing to instability in northern Ethiopia. Eritrean forces have supported Ethiopian troops in their battle against the rebel Tigray People Liberation Front (“TPLF”).  The US has roundly condemned the hostilities, accusing all sides of committing atrocities, and has threatened to impose measures on the Ethiopian government and the TPLF.

• In reaction to Belarussian moves aimed at facilitating the illegal entry of migrants into Poland to claim asylum, the EU has altered its legislation, allowing it to sanction actors contributing to the crisis. The measure is widely expected to be used in the near future against Belarussian national airline BelAvia, which has been transporting migrants from their home countries into Belarus.  Elsewhere, the UK has introduced legislation which will see its sanctions programme against Belarus enforced in the Isle of Man and British Overseas Territories.

• The US continues to oppose the construction of the now-almost completed Nord Stream 2 pipeline between Russian and Germany. In November, a Russian pipe laying vessel and its parent company were sanctioned by the US.  German efforts to assuage US concerns over the project appear to be making headwind in the Biden administration, and the two countries are expected to make a joint statement regarding Nord Stream 2 in the near future.

• On 11^th November the US, EU and UK sanctioned senior Houthi military leaders in Yemen over their involvement in military actions in Marib in Saudi Arabia. The designations followed measures imposed by the UN Security Council against the same individuals.

• The US has imposed measures under its Global Magnitsky sanctions programme, against two senior Cambodian military figures, Chau Phirun (Director-General of the Cambodian Defence Ministry’s Material and Technical Services Department) and Tea Vinh (Royal Cambodian Navy Commander), due to their involvement in significant corruption; both were accused of skimming state funds meant for the construction of a naval base.

• The US has terminated its Burundi sanctions programme, which had been in place since 2015. The termination sees sanctions against eight powerful military and security officials lifted following reforms introduced by current President Évariste Ndayishimiye.

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• On 18^th October 2021 the US Treasury Department released a report containing the findings of its 2021 Sanctions review, commissioned by Secretary of the Treasury Janet Yellen. The review provides important early insights into how the Biden administration intends to deploy financial sanctions and, as expected, emphasised its commitment to highly targeted programmes and co-ordination with its allies – representing something of a break with the policies pursued under its predecessor.  Also of note is the Treasury’s continued engagement with the world of cryptocurrency, which is described in the review a threat to the volume of dollar-denominated international transactions and therefore the effectiveness of US sanctions.  On 11^th October 2021 OFAC published a brochure entitled Sanctions Compliance Guidance for the Virtual Currency Industry, setting out in detail the sanctions compliance obligations incumbent on crypto currency service providers and including a case study of an OFAC sanctions violation involving virtual currency.  On 21^st September 2021, OFAC sanctioned cryptocurrency exchange Suex for having facilitated transactions involving illicit proceeds from a series of eight ransomware attacks.

• On 1^st October 2021 the US House of Representatives passed two bills which would authorise additional US sanctions if they subsequently become law. One of these, the National Defence Authorisation Act for Fiscal Year 2022, would end the current national interest waiver on Nord Stream 2-related sanctions and authorise mandatory sanctions on foreign entities involved in the planning, construction and operation of the pipeline.  The bill will now be debated by the Senate.

• On 14^th October 2021 OFSI published its 2020-2021 Annual Review, providing a factual overview of its activity over the financial year. The Review noted 278 new designations during this period and the freezing of £12.2 billion worth of assets in the UK under sanctions regulations as of September 2020.  A total of £11.53 billion of this amount is connected to the Libyan government.  The Annual Review reaffirmed the UK’s autonomy with regards to sanctions policy post-Brexit and committed OFSI to playing a central role in the government’s economic crime agenda.

• On 8^th October 2021 OFAC delisted Tehran-headquartered Mammut Industrial Group and its subsidiary Mammut Diesel. The group had been designated in September 2020, having been deemed to be supplying “military grade, dual-use goods” to Iran’s Shahid Hemmat Industrial Group, which manufactures liquid-propelled missiles.  OFAC subsequently denied reports that the move was linked to ongoing talks in Vienna over the potential revival of the JCPOA.

• Key designations this month include the EU and shortly thereafter SECO’s listing of eight members of the Russian judiciary and security officers deemed to have contributed to the undermining of the territorial integrity of Ukraine by “enforcing Russian law in the illegally-annexed Crimea and Sevastopol.” Other new designations include the addition of Osama Al Kuni Imbrahim to the UN’s Libyan sanctions list and OFAC’s imposition of sanctions against Jaime Humberto Higuera Gonzalez, known as “El Tunco”, under its Counter Narcotics program.

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• On 17^th September 2021 OFAC introduced a new sanctions programme targeting those deemed to have been involved in perpetuating violence in the north of the country. The region has suffered several violent episodes due to conflict between the Ethiopian National Defence Forces and the Tigray Peoples’ Liberation Front, which controls much of the north.  Both sides have been accused of committing atrocities and the US measures mean that government officials and military leaders can be sanctioned in addition to armed opposition factions, as well as those seen to be obstructing peace efforts.

• The US has released two general licences in respect of its Afghanistan programme which authorise the delivery of humanitarian goods and services to the country. These activities would otherwise have been affected by US sanctions on dealing with the Taliban.  The exemptions apply to transactions involved in the exportation of agricultural commodities, medicine, medical devices and other goods essential for basic human needs.

• The EU appears set to tighten sanctions measures on Lebanon following the adaptation of a strongly worded resolution passed by the European Parliament in September 2021 condemning Lebanese political parties for their role in the country’s ongoing economic crisis. Further measures may be taken against individual politicians who seek to contest the mandate of the newly formed government, led by Prime Minister Najib Mikati, and efforts to resolve the country’s dire economic situation.  There have been several accusations in the media that members of the country’s political and economic elite have co-operated to block an IMF-led bailout in order to protect their interests in the Lebanese banking sector.

• The US has updated its sanctions programme against Russia following the poisoning of Russian opposition politician Alexey Navalny in 2020. The updated sanctions measures, enacted under the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991, mean that the US will oppose any multilevel development bank assistance offered to Russia and prohibit any US bank from making any loans to the Russian government.  It has also instituted a ban on the importation of weapons and ammunition manufactured in Russia.

• The UK has further increased pressure on Myanmar by sanctioning prominent businessman Tay Za, who is the majority shareholder of the Htoo Group of Companies. The Htoo conglomerate has interests across Myanmar’s aviation, construction, timber, shipping, mining and tourism sectors.  The UK accuses Za of supporting the country’s military junta and participating in deals which violated an arms embargo on the country’s military.  Several rounds of sanctions against Myanmese government entities and businesspersons have been imposed since the February 2021 military-led coup.

• Elsewhere, there have been several new designations by the US of individuals accused of supporting Al Qaida and Hezbollah and the first ever sanctioning of a cryptocurrency exchange for facilitating ransomware payments. There have also been a number of prosecutions of persons  in the US over the course of the month for violations of Iran and North Korea sanctions programmes.

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• The sudden and dramatic fall of the Government of Afghanistan to the Taliban has seen the US freeze over $9 billion in Afghan Central Bank reserves. Senior Taliban figures already feature across UN, US, EU and UK sanctions programmes and there is now considerable speculation over whether the country’s government will now be sanctioned by the international community following their seizure of power.  President Biden has indicated that any future sanctions regime imposed on Afghanistan will depend on the conduct of its new government and its approach to human rights.  The US has indicated that it will continue to help humanitarian organisations delivering aid to the country in a manner consistent with the existing sanctions programmes.

• August 2021 saw the US prosecute several individuals and entities for contravening its sanctions regime on Iran. Early in the month a US-domiciled Iranian citizen was charged for the illegal export of laboratory equipment, while a US veterinary company is currently being investigated for its Iranian dealings.  An Omani oil broker called Mahmood Rashid Amur Al Habsi and several associated entities have been sanctioned for running an Iranian oil smuggling operation.  Elsewhere, the US has released a General License permitting the export of certain graduate-level software for use in Iranian educational facilities.

• Measures have been strengthened this month against the Government of Belarus, with the Swiss replicating EU sanctions against the country first introduced in June 2021. The UK has itself introduced a new package of trade sanctions targeting the country’s trading, financial and aviation sectors.  The US has also expanded its Belarus sanctions programme, targeting 44 individuals and entities in the country’s government as well as Belarussian financial institutions and OAO Belaruskali, a state-owned potash manufacturer.

• The US and UK have imposed additional sanctions on employees of the Russian state security apparatus suspected to have been involved in the poisoning of Russian opposition politician Alexey Navalny. Elsewhere, the US has imposed additional restrictions on those involved in the German-Russian gas pipeline Nord Stream 2 project, targeting a pipe-laying ship and its parent entity as well as a Russian insurance company.

• The US has also sanctioned the Cuban police body, Policia Nacional Revolucionaria, under its Global Magnitsky Programme aimed at curbing human rights abuses worldwide in relation to its suppression of protests in the country. Three officials in the Cuban Ministry of the Interior have also been added to the list of targets under the programme.

• Several measures were deployed in August against Nicaraguan nationals deemed to be involved in human rights abuses and attacks on democracy. Tens of individuals were the subject of US-imposed visa restrictions, while EU sanctions were imposed on eight individuals.

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• Following the conclusion of an agreement between the US and Germany over the Nord Stream 2 pipeline, on 21^st June the countries issued a joint statement titled ‘Support for Ukraine, European Energy Security, and [their] Climate Goals’ which noted, amongst other things, that both governments remain committed to the idea of imposing sanctions in response to any future malign activities perpetrated by Russia. The statement was widely characterised in the media as having been designed to assuage concerns held by the Ukrainian and Polish governments relating to the pipeline’s security implications.

• The EU Parliament has adopted multiple resolutions calling for the imposition of sanctions pursuant to the EU Global Human Rights Sanctions Regime, specifically urging designations in China and Hong Kong, including Carrie Lam, as well others in Saudi Arabia, Iran and Nicaragua. On 12^th July the EU Foreign Affairs Council decided in principle to establish a new sanctions regime targeting the Lebanese leaders responsible for the country’s “political stalemate”, economic crisis and the “suffering” of the Lebanese people.  The relevant resolutions and council decisions are yet to be formally ratified.

• The Swiss Federal Council has joined the EU in listing 78 people and seven entities under its Belarus sanctions regime, as well as eight individuals and four entities in response to human rights violations in Myanmar. The listings track the most recent round of EU sanctions imposed over the Myanmar military coup and situation in Belarus.

• The UK Foreign Affairs Committee has published a report entitled ‘Never Again: The UK’s Responsibility to Act on Atrocities in Xinjiang and Beyond’. The report recommends that the UK Government responds to the “atrocities” committed by the Chinese state in the Xinjiang Uyghur Autonomous Region.  OFSI has also penned a blog post titled ‘Reasonableness in licencing’, to provide guidance on the information OFSI considers when adjudicating an application to licence frozen funds for legal fees or maintenance of funds and frozen resources under the UK Sanctions Act.

• This month’s high-profile designations further included the following:

1. OFAC’s designations of 14 individuals in El Salvador, 20 in Guatemala and 21 in Honduras who have “knowingly engaged in actions that undermine democratic processes or institutions” and “significant corruption”.
2. An asset freeze targeting seven key members of the Myanmar military and 15 of the spouses and adult children of previously designated senior Burmese military officials.
3. 100 individuals associated with the Ortega-Murillo regime, including members of the Nicaraguan National Assembly and the Nicaraguan judiciary, as well as some of their family members, have been targeted with US visa restrictions
4. Cuban Minister of the Revolutionary Armed Forces Álvaro López Miera and the Cuban Ministry of the Interior’s Brigada Especial Nacional have been added to the OFAC SDN list.

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• The G7 summit held between 11^th and 13^th June in Cornwall ended with a joint statement announced by the G7 states in which they committed to working together to impose sanctions on those responsible for the forced landing in Minsk of a Ryanair aircraft carrying prominent Belarussian opposition activist, Roman Protasevich. They also agreed to work towards implementing sanctions relating to North Korea’s weapons of mass destruction and ballistic missile programmes.  Following the summit, the EU and US leaders announced their intention to “enhance cooperation in the use of sanctions to pursue shared foreign policy and security objectives” with a specific focus on ongoing JCPOA diplomatic talks in Vienna.

• Thus far the EU council has been the only relevant entity to enact new sanctions in respect of Belarus. On 24^th June it published new council resolutions prohibiting an array of transactions that might facilitate improper activity by the Belarussian authorities.  The new measures are focussed on preventing companies from supplying Belarusian government agencies with the means to monitor or intercept mobile communications.

• In the US President Biden has revoked executive orders passed by President Trump which prevented US companies from transacting with Chinese social media platforms TikTok and WeChat. He has expanded the scope of additional Chinese sanctions by issuing a new executive order “Addressing the Threat from Securities Investments and Finance Certain Companies of the People’s Republic of China”.  This resulted in the designations of a further 59 Chinese entities.

• On 9^th June 2021 OFAC announced the expansion of its Western Balkans sanctions regime. President Biden signed a new executive order effecting this expansion, implementing an asset freeze and imposing travel bans against persons deemed to be contributing to destabilising the situation in the region.  The move was characterised by the US press as representative of the Biden administration’s desire to present itself as taking a more active role in advocating for democratic principles.

• The EU Parliament Foreign Affairs Committee has adopted a resolution calling for corruption to be added as sanctionable conduct under the EU Global Human Rights Sanctions Program. Adopted in December 2020, the program currently only targets people or entities deemed responsible for serious human rights violations.

• A US district court has dismissed a complaint filed by Russian oligarch Oleg Deripaska seeking to challenge his designation by OFAC. The court granted OFAC’s motion for a summary judgement after Deripaska alleged the US Department of the Treasury had made false allegations based on rumour and innuendo to support the sanctions.

• In Iran Ebrahim Raisi was announced the winner of the country’s presidential election on 19^th Since November 2019 President-elect Raisi has been subject to a US asset freeze pursuant to OFAC’s Iranian sanctions program.

• Key OFAC designations this month include former Namibian ministers Bernhardt Esau and Sakeus Shanghala for their alleged involvement in a corruption scandal, Bulgarian businessman Vassil Kroumov Bojkov, a Guatemalan Congressperson, four Nicaraguan government officials, and a Houthi financier.

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• The forced landing in Minsk of a Ryanair aircraft carrying a prominent Belarussian opposition activist, Roman Protasevich, co-ordinated by Belarussian authorities, has drawn condemnation from Western politicians. Protasevich played a crucial role in mobilising opposition protests in the wake of the disputed August 2020 Presidential Election.  On 25^th May EU leaders agreed to impose further sanctions on the country, although no further details on the exact measures have been announced to date.  Press reporting indicates that the one of the country’s largest exports, potash, may become subject to EU trade restrictions.

• In a climbdown from its previous position, the US government has waived imposing sanctions against Nord Stream 2 AG, a German entity overseeing the construction of the controversial pipeline between Russia and Germany, as well as the company’s CEO, Matthias Warnig. Despite the State Department finding that US sanctions programmes had been breached, no penalties were imposed due to concerns for the US-German relationship.  To date, four Russian entities and 13 vessels are sanctioned under the Protecting Europe’s Energy Security Act (“PEESA”), which targets the project.

• In a coordinated move, the UK, US and Canada have tightened their sanctions regime against Myanmar. The US has sanctioned the State Administrative Council (“SAC”) and 13 officials, while the UK has sanctioned state-owned entity Myanmar Gems Enterprise, which was designated under US measures in the previous month.  Since February 2021, when the country’s military overthrew the democratically elected government, sanctions on the country have been gradually expanded.

• The US continues to impose sanctions on Chinese individuals for human rights violations, recently sanctioning Chinese Communist Party official Hu Yui for persecution of minorities including Uyghur Muslims and worshippers of other faiths in China. A long-planned trade agreement between the EU and China has been derailed due to rising tensions between the two.  The EU withdrew from the deal after China sanctioned EU parliamentarians who have decried human rights violations in the country.  The Chinese sanctions were tit-for-tat measures imposed after the EU sanctioned officials involved in implementing controversial Chinese policies in Xinjiang.

• Informal talks in Vienna between the US and Iran are continuing regarding a rollback of US sanctions. In the latest move, the US has offered to withdraw its sanctions on Iran’s oil industry, although this is contingent on Iran returning to commitments to reduce its refinement of nuclear material under the Obama-era JCPOA agreement.

• Elsewhere, the US has sanctioned Libyan militia Al Khaniyat as well as the organisation’s senior leadership, a senior commander of the Houthi rebels in Yemen. Separately, the US has added  four Turkish citizens to its sanctions lists for providing financial support to ISIS.

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• On 15^th April 2021 the US significantly expanded its sanctions against Russia by further targeting individuals and entities linked with Russia’s offensive cyber capabilities as well as restricting the Russian Government’s ability to raise financing on the global markets. Over 40 individuals and companies have been added to the SDN list due to their involvement in Russian malign activities, such as the SolarWinds hack and interference in the US 2020 Presidential election.  From 14^th June, US financial institutions are prohibited from participating in the primary market for new debt issued by the Central Bank of Russia, the Finance Ministry and Russian sovereign wealth funds.

• The Biden administration explained that the new sanctions were in response to Russia’s past transgressions, stating that they were not aimed at escalating tensions between Russia and the west, especially in the context of Russia military build-up on the border with Ukraine. The US President expressed a desire for a “stable and predictable” future relationship with Russia when announcing the package.  The measures are not as severe as some commentators suggested prior to the announcement.

• In the UK, a new sanctions programme has been introduced targeting individuals engaged in corruption. Some of the first additions to the list include 14 Russian nationals linked to the so-called Magnitsky case, most of whom were already targeted under US programmes, as well as the three Gupta brothers, who have been accused of corruption on a large scale in South Africa.  Announcing the measures, UK Foreign Secretary Dominic Raab underlined that the UK was taking steps to combat the proceeds of crime being laundered in the UK.

• Elsewhere, the US and UK have ratcheted up pressure on the Myanmar military over its February 2021 coup d’état by including more senior figures on their sanctions programmes, while OFAC has designated major state-owned conglomerates and a military-linked state gemstones company.

• Rumours over the US relaxing its sanctions measures against Iran continue to circulate in the press, although no action has yet been taken by the Biden administration. According to the latest reporting, the US is considering a wide-ranging rollback of measures implemented by the Trump administration in a move towards reviving the JCPOA.

• In another break with Trump-era policy, the new Biden administration has revoked OFAC’s International Criminal Court sanctions program. The sanctions had previously enforced an asset freeze against a number of senior officials of the court as an expression of the US’s longstanding diplomatic objection to the ICC’s efforts to assert jurisdiction over the US and Israel in Afghanistan and the Palestinian Territories.  The new administration described the sanctions as inappropriate and ineffective.

• Despite US pressure, Germany in April reaffirmed its commitment to the Nord Stream II project with Russia. Russian ships have in recent days restarted pipelaying operations for the delayed project.  It remains unclear whether the US will follow through on threats to impose sanctions on Berlin, although most observers believe this outcome to be unlikely.

• Other notable designations this month include OFAC’s sanctioning of another raft of Mexican nationals under the so-called Kingpin Act, two senior Guatemalan officials for corruption and two Pakistani leaders of a global smuggling organisation. The EU has designated eight senior officials and two prisons in Iran over human rights abuses.

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• The UK government has published its Integrated Review of Security, Defence, Development and Foreign Policy, which states that the Government intends use sanctions to “act as a force for good in standing up for human rights around the world”, to hold to account those involved in “serious human rights violations and abuses”, and to stand up for “national security diplomacy”.

• Further steps were taken in support of this purpose alongside the EU on 22^nd March, with asset freezes and travel bans imposed on four senior Chinese officials and a state-run security body for serious human rights violations relating to the treatment of the Uighur population of Xinjiang. OFAC had previously taken action in relation to Xinjiang on 17^th March, adding 24 Chinese officials to its list of specially designated nationals under Executive Order 13936.

• Another theme this month has been action against Russia. The US State Department has issued a press statement saying that it is “tracking efforts to complete the Nord Stream 2 pipeline and is evaluating information on entities that seem to be involved.”  It warns that entities involved in the pipeline risk exposure to sanctions and advises that they should cease work on the project.

• Also in relation to Russia, the EU has made designations under its new global human rights program for the first time, sanctioning four Russian officials for serious human rights violations. OFAC designated seven senior Russian officials on the same day.  Both measures were in response to the poisoning and subsequent imprisonment of Alexei Navalny.  OFAC has also issued a general license authorising certain transactions with the FSB necessary for its administrative and law enforcement capacities.

• There remains little movement with regard to the Iranian sanctions programme. Iran’s Foreign Ministry has declined a proposal put forward by Josep Borrell, the EU High Representative and JCPOA coordinator, to attend an unofficial meeting of signatories to the nuclear deal and the US, in a further sign that the resumption of talks remains a distant prospect.

• On 12^th March the EU Council revoked its framework that established a sanctions regime against people identified as responsible for the misappropriation of state funds in Egypt. As a result, sanctions currently targeting nine Egyptian nationals were lifted.  The framework was first introduced in 2011 in the aftermath of the Arab Spring.

• Senior US administration officials have confirmed plans to review the effectiveness of the US sanctions regime against Venezuela. The decision follows publicised concerns that “unilateral sanctions, over the last four years, have not succeeded in achieving an electoral outcome in the country”, and that the Maduro regime has adapted to sanctions and sustained itself through illicit activity.

• After the UN Special Envoy for Myanmar, Christine Schraner Burgener, called on member states to impose “hugely strong measures” against the Burmese military following the coup on 1^st February, the EU designated eleven Burmese officials who are alleged to have been involved.

• The US State Department has imposed a travel ban on Ukrainian oligarch Igor Kolomoisky due to his alleged involvement in significant corruption. Kolomoisky is currently accused of misappropriating deposits worth several billions from the now state-owned Privatbank.

• Additional designations include US State Department’s imposition of visa restrictions on 76 Saudi nationals, and the listing of two under Global Magnitsky sanctions, following the publication of an intelligence report which assessed that Crown Prince Muhammad bin Salman had approved the operation to capture or kill Jamal Khashoggi in October 2018. OFAC has also designated Juan Manuel Abouzaid El Bayeh, a citizen of Mexico, as a specially designated narcotics trafficker.

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