Sanctions were first imposed by the UN in 1999, targeting individuals involved in the Taliban Government, which administered the country from 1996 until 2001. Subsequent programmes, instituted following the US-led invasion of the country in 2001, have targeted insurgent groups tied to the Taliban and parties deemed to be close to Al-Qaeda. No further sanctions have been imposed on the Taliban or Afghanistan’s government since the Taliban restored control over the country in August 2021 and legislation has since been introduced to facilitate certain interactions with the country.

Sanction Name

UN Sanctions Against Afghanistan

First Imposed

June 17, 2011

Last updated

December 14, 2023

Targets

Asset Freeze and Travel Ban:
• Members or associates of the Taliban or Al-Qaeda

Arms Embargo:
• Members or associates of the Taliban or Al-Qaeda

Exemptions

1. The UN legislation allows for some exemptions to an asset freeze for an individual to meet with the ombudsman to challenge inclusion on the sanctions list.

2. Individuals are permitted to travel to other jurisdictions for the fulfilment of judicial processes.

3. On 23rd December 2021 the UN Security Council unanimously adopted resolution 2615, which establishes an exemption from Taliban-related sanctions for humanitarian assistance and other activities that support basic needs in Afghanistan.

Sanction Name

EU Sanctions Against Afghanistan

SANCTIONS

Asset Freeze, Arms Embargo, Travel Ban,

First Imposed

August 5, 2011

Last updated

April 13, 2022

Targets

Asset Freeze and Travel Ban:
• Members or associates of the Taliban or Al-Qaeda

Arms Embargo:
• Members or associates of the Taliban or Al-Qaeda

Exemptions

1. Asset Freeze exemptions are permitted for certain legal and basic expenses.

On 11th February 2024 the US extended Executive Order 14064 regarding the situation in Afghanistan for a year until 11th February 2025.

Sanction Name

US Sanctions against Afghanistan

SANCTIONS

Asset Freeze, Arms Embargo, Travel Ban,

First Imposed

September 23, 2001

Last updated

February 11, 2024

Targets

Asset Freeze and Travel Ban:
• Members or associates of the Taliban or Al-Qaeda

Arms Embargo:
• Members or associates of the Taliban or Al-Qaeda

Exemptions

1. Individuals subject to travel bans are permitted entry or transit when participating in judicial processes or when travelling to their country of nationality.

2. Asset freeze exemptions are considered on a case-by-case basis for certain expenses.

3. On 24th September 2021 the US issued a General Licence permitting the export to Afghanistan of agricultural commodities, medicine, medical devices, replacement parts and components, as well as software updates.

4. On 10th December 2021 OFAC issued General License 16, which authorises transactions involving the Taliban or the Haqqani Network that are necessary to the transfer of non-commercial personal remittances to Afghanistan.

5. On 22nd December 2021 OFAC issued General Licenses 17, 18 and 19, adding exemptions for personal remittances and for the provision of humanitarian assistance to a range of civil society bodies under the control of the Taliban or Haqqani network.

6. On 25th February 2022 OFAC issued General License 20, which authorises transactions involving Afghanistan and/or governing institutions in Afghanistan. However, the license does not permit: a) financial transfers to the Taliban, Haqqani Network or any entity involved in either organisation, b) any person who is a leader of either organisation who is blocked under existing sanctions regulations (with some exemptions for the payment of taxes or import duties and public utility services, as long as these do not constitute luxury goods or services) c) any debit to the US account of a blocked person, or d) transactions with any person who is personally sanctioned, unless separately authorised.

Sanction Name

The Afghanistan (Sanctions) (EU Exit) Regulations 2020

SANCTIONS

Asset Freeze, Arms Embargo, Travel Ban,

First Imposed

December 31, 2020

Last updated

February 16, 2022

Targets

Asset Freeze and Travel Ban:
• Members or associates of the Taliban or Al-Qaeda

Arms Embargo:
• Members or associates of the Taliban or Al-Qaeda

Exemptions

1. Asset Freeze exemptions are permitted for certain legal and basic expenses.

In February 1992 the Organisation for Security and Co-operation in Europe (OSCE) requested that all participating states should introduce an embargo on ‘all deliveries of weapons and munitions to forces engaged in combat in the Nagorno-Karabakh area’. This embargo is still in effect.

Sanction Name

Export Control Order 2008

First Imposed

December 31, 2020

Last updated

January 10, 2023

Targets

Trade Embargo
The embargo covers the export, supply or delivery of all goods and items on the UK military list where this equipment could be used:
• in the Nagorno-Karabakh region
• on the land border between Azerbaijan and Armenia

Exemptions

1. Supplies of military list equipment to other end-users – such as humanitarian, peacekeeping, research or media organisations – will not be considered subject to the embargo, unless there is a clear risk of diversion to the armed forces, police, or security forces of either Armenia or Azerbaijan.

In February 1992 the Organisation for Security and Co-operation in Europe (OSCE) requested that all participating states should introduce an embargo on ‘all deliveries of weapons and munitions to forces engaged in combat in the Nagorno-Karabakh area’. This embargo is still in effect.

Sanction Name

Export Control Order 2008

First Imposed

December 31, 2020

Last updated

January 10, 2023

Targets

Trade Embargo
The embargo covers the export, supply or delivery of all goods and items on the UK military list where this equipment could be used:
• in the Nagorno-Karabakh region
• on the land border between Azerbaijan and Armenia

Exemptions

1. Supplies of military list equipment to other end-users – such as humanitarian, peacekeeping, research or media organisations – will not be considered subject to the embargo, unless there is a clear risk of diversion to the armed forces, police, or security forces of either Armenia or Azerbaijan.

Various sanctions have been imposed in relation to the break-up of the former Yugoslavia dating to the early 1990s, by OFAC, the EU and the UN. Two programmes currently remain in force: one OFAC programme targeting individuals tied to ethnic violence and war crimes in the 1990s and an EU programme focussed on protecting the territorial integrity of Bosnia and Herzegovina.

On 18th March 2022 the EU renewed its Balkans sanctions program until 31st March 2024. As of 31st March 2024 the EU has announced no updates but these sanctions are likely to be renewed.

Sanction Name

Council Decisions Concerning Restrictive Measures In Bosnia And Herzegovina

First Imposed

March 22, 2011

Last updated

November 29, 2023

Targets

Asset Freeze and Travel Ban:
• No individuals are currently listed although the legislative framework remains in place.

Exemptions

1. Exemptions can be granted on a case-by-case basis for humanitarian grounds or in relation to the attendance of inter-governmental meetings.

On 13th March 2023, OFAC designated three individuals who have contributed to Specially Designated National (SDN) and Republika Srpska (RS) President Milorad Dodik’s (Dodik) efforts to undermine the peace and stability of Bosnia and Herzegovina (BiH) by organizing and executing the commemoration of “Republika Srpska Day” (RS Day) on January 9, 2024, an activity determined to be unconstitutional in BiH. These individuals facilitated Dodik’s efforts to undermine the Dayton Peace Agreement (DPA) and the authority of the BiH Constitutional Court and the High Representative.

Sanction Name

Blocking of Persons Who Threaten International Stabilization Efforts in the Balkans

SANCTIONS

Specially Designated National, Asset Freeze, Travel Ban,

First Imposed

June 27, 2001

Last updated

March 13, 2024

Targets

Specially Designated National:
• Individuals and entities linked to violence, acts of aggression, and those deemed to be undermining democratic institutions and processes for political gain.

Exemptions

1. US lawyers are permitted to represent persons whose property, or interests in property, have been blocked as part of cases heard in the International Criminal Tribunal for the former Yugoslavia.

Beginning in 2004, in the run-up to the country’s 2006 Presidential election, the EU and the US have imposed increasingly stringent sanctions against Belarus, seeking to counter an increase in political repression. Most of these measures were discontinued in 2016, reflecting the view that the conduct of the Belarus government had improved. In September and October 2020 new sanctions were placed on senior members of the Administration for alleged ballot fraud in the country’s Presidential Election. Sanctions pressure steadily increased on Belarus throughout 2021, including the increased targeting of state-owned companies and government officials. In 2022 Belarus faced further sanctions linked to its role in the Russian-led invasion of Ukraine.

On 26th February 2024 the EU renewed its sanctions programme on Belarus until 28th February 2025.

Sanction Name

Restrictive Measures In Respect Of Belarus

First Imposed

May 18, 2006

Last updated

February 26, 2024

Targets

Asset Freeze and Travel Ban:
• Individuals suspected to be involved in the unresolved disappearances of four Belarusian citizens between 1999 and 2000.

• Senior personnel of the Belarussian administration, those considered to be close to President Lukashenko, including the President himself, as well as senior military figures for the their role in Russia’s invasion of Ukraine.

Trade Restriction:
• Exportation of equipment or the provision of technical or financial assistance which may be used for internal repression. This includes a ban on the trading of equipment, technology or software intended primarily for use in the monitoring or interception of the internet and of telephone communications and dual-use goods and technologies for military use and to specified persons, entities or bodies in Belarus.

• On 3rd March 2022 the EU prohibited the sale, supply, and export of any military technology to Belarus via export controls. On 10th March 2022 prohibited the provision of SWIFT services to Belagroprombank, Bank Dabraabbyt and the Development Bank of the Republic of Belarus and their subsidiaries, as well any euro denominated transactions with any person or entity in Belarus or for use in Belarus.

Exemptions

1. Exemptions to travel bans can be granted on a case-by-case basis for humanitarian grounds or for attending inter-governmental meetings.

2. Certain types of small-calibre sporting rifles, pistols and ammunition.

Sanction Name

Regulation on measures against Belarus

SANCTIONS

Asset Freeze, Travel Ban,

First Imposed

June 28, 2006

Last updated

March 22, 2024

Targets

Asset Freeze and Travel Ban:
• Individuals suspected to be involved in the unresolved disappearances of four Belarusians between 1999 and 2000

• Senior personnel of the Belarussian administration and those considered to be close to President Lukashenko; Lukashenko himself is not subject to sanctions.

Exemptions

1. Travel ban exemptions may be granted on a case-by-case basis on humanitarian grounds or in relation to the attendance of meetings of international organisations concerning politics in Belarus, or for the protection of Swiss interests.

2. Asset freeze exemptions may be granted to protect Swiss interests or to prevent cases of rigor.

On 5th December 2023 OFAC issued General License 10, authorising the wind down of transactions necessary to the wind down of any transaction involving Tabak Invest LLC. The same day, OFAC designated 11 entities and eight individuals to increase pressure on Alyaksandr Lukashenka’s regime for its suppression of Belarus’ democratic civil society, the corrupt financial enrichment of the Lukashenka family, and for its complicity in Russia’s war against Ukraine.

Sanction Name

Specially Designated Nationals For Certain Persons Undermining Democratic Processes or Institutions in Belarus

SANCTIONS

Specially Designated National,

First Imposed

June 20, 2006

Last updated

December 5, 2023

Targets

Specially Designated National:
• Individuals involved in human rights abuses, political repression, ballot fraud and public corruption.
• Individuals and entities operating in the defence, security, energy, potash, tobacco, construction and tobacco sectors which have engaged in actions threatening the peace, security or territorial integrity of Belarus.
• On 9th August 2021 President Biden signed Executive Order 14038, Blocking Property of Additional Persons Contributing to the Situation in Belarus, expanding the scope of the previous Executive Order to include individuals and entities operating in a range of sectors including defence, security, energy, potash, tobacco, construction and transportation.

Exemptions

1. OFAC has authorised transactions with nine entities that would otherwise have been prohibited. US persons engaging in transactions exceeding $50,000 with these entities are required to file a report with the US Department of State, Office of Eastern European Affairs within 30 days of the transaction.
2. On 24th February 2022 OFAC released two General Licenses (6 & 7), the first of which authorised all transactions relating to official US government business. General License 7 permitted all transactions related to the UN and its related organisations, the International Centre for Settlement of Investment Disputes (“ICSID”) and the Multilateral Investment Guarantee Agency (“MIGA”), a number of continental development banks such as the EBRD and the business of the Red Cross.
3. On 9th August 2023 OFAC issued Belarus General License 8, authorising the wind down of transactions involving Byelorussian Steel Works Management Company, and Belarus General License 9, authorising transactions related to civil aviation safety or the winding down of dealings with Belavia Belarusian Airlines.
4. On 5th December 2023 OFAC issued general License 10, authorising certain transactions involving Tabak Invest LLC.

Sanction Name

Republic of Belarus (Sanctions)(EU Exit) Regulations 2019

SANCTIONS

Asset Freeze, Travel Ban,

First Imposed

December 31, 2020

Last updated

February 22, 2024

Targets

Asset Freeze and Travel Ban:
• Individuals suspected to be involved in the unresolved disappearances of four Belarusian citizens between 1999 and 2000.

• Senior personnel of the Belarussian administration, including President Lukashenko himself, as well as those deemed to have facilitated Russia’s invasion of Ukraine via supplying to the country’s military.

• Individuals and entities which:
i) Hold the right to nominate a director or trustee of a government-affiliated entity or who work for the government of Belarus
ii)Obtain a financial benefit from, and immediate family members of, individuals involved in the disappearances of opposition figures Yury Zakharanka, Viktar Hanchar, Anatol Krasouski or Dmitry Zavadski in 1999 and 2000.

Trade Restriction:
•Export of equipment or the provision of technical or financial assistance which may be used for internal repression or in support of Russia’s invasion of Ukraine, as well as a number of strategic sectors including diamonds and rubber.

•Export of banknotes, chemical and biological weapons-related goods and machinery-related goods, as well as the importation from Belarus of gold, gold jewellery, cement, rubber, and wood.

Other
•An obligation for social media services and internet service providers to ensure that they take a reasonable steps to prevent users from accessing online content generated by designated persons.

Exemptions

1. Exemptions to travel bans can be granted on a case-by-case basis on humanitarian grounds or to enable the attendance of inter-governmental meetings.

2. Certain types of small-calibre sporting rifles, pistols and ammunition are exempted from the arms embargo.

3. On 12th July 2022 OFSI extended its Belarus sanctions program, expanding the criteria for designation to those providing logistical support to the Russian army, spreading disinformation, or acting in sectors deemed to be of economic or strategic significance to the government’s support for the invasion of Ukraine. Transport-related amendments have prohibited Belarussian ships from entering UK ports and conferred powers on the Secretary of State to detain Belarusian ships at UK ports or anchorages.

4. On 17th October 2022 OFSI indefinitely authorised designated people or entities under its Belarus sanctions program to pay funds to the London Court of International Arbitration to cover arbitration costs, and the LCIA to direct and receive any such funds to pay for arbitration costs.

Sanction Name

Restrictive Measures in view of the situation in Bosnia and Herzegovina

First Imposed

March 20, 2012

Last updated

November 29, 2023

Targets

Asset Freeze and Travel Ban:
•Individuals who undermine the sovereignty, territorial integrity, constitutional order and international personality of Bosnia and Herzegovina; seriously threaten the security situation in Bosnia and Herzegovina.

Sanction Name

Bosnia and Herzegovina (Sanctions)(EU Exit) Regulations 2020

SANCTIONS

Asset Freeze, Travel Ban,

First Imposed

December 31, 2020

Last updated

January 15, 2024

Targets

Asset Freeze and Travel Ban:
•Individuals who undermine the sovereignty, territorial integrity, constitutional order and international personality of Bosnia and Herzegovina or seriously threaten the security situation in Bosnia and Herzegovina.

Measures were first imposed on a small number of Burundi nationals in 2015 following a failed coup d’état by the country’s military.

On 23rd October 2023, the EU renewed its Burundi sanctions regime for one year until 31st October 2024. Currently, the Burundi regime only applies to Mathias-Joseph Niyonzima, an officer of the National Intelligence Service, who is subject to an asset freeze and travel ban.

Sanction Name

Council Decisions Concerning Restrictive Measures In Burundi

First Imposed

October 2, 2015

Last updated

November 29, 2023

Targets

Asset Freeze and Travel Ban:
• Individuals involved in the abuse of human rights, those contributing to internal instability and threatening democratic rule.

Exemptions

1. Exemptions can be granted on a case-by-case basis for humanitarian grounds or to support the attendance of inter-governmental meetings.

Sanction Name

Regulation on Measures Against Burundi

SANCTIONS

Asset Freeze,

First Imposed

December 1, 2015

Last updated

March 15, 2024

Targets

Asset Freeze:
• Individuals involved in abuse of human rights, contributing to turmoil and threatening democratic rule.

Exemptions

1. Asset freeze exemptions may be granted to protect Swiss interests, to prevent cases of rigor, to respect existing contracts or to respect credits due under existing judicial, administrative or arbitral judgments.

Sanction Name

Burundi (Sanctions) (EU Exit) Regulations 2019

SANCTIONS

Asset Freeze, Travel Ban,

First Imposed

December 31, 2020

Last updated

July 7, 2022

Targets

Asset Freeze and Travel Ban:
• Individuals involved in the abuse of human rights, those contributing to internal instability and threatening democratic rule.

Exemptions

1. Exemptions can be granted on a case-by-case basis for humanitarian grounds or to support the attendance of inter-governmental meetings.

Sanctions were imposed following the outbreak of civil war in 2012 and target individuals and entities known to have breached human rights or attacked peacekeepers.

On 27th July 2022 the arms embargo was extended until 31st July 2024.

Sanction Name

UN Sanctions Against the Central African Republic

First Imposed

December 5, 2013

Last updated

July 27, 2023

Targets

Asset Freeze and Travel Ban:
• Individuals and entities involved in the civil war who have committed war crimes and other abuses of human rights.
• Persons and entities suspected of financing war efforts through the illicit sale of the country’s natural resources.

Arms Embargo:
• All deliveries of arms and other military equipment and supplies to the Central African Republic are prohibited.

Exemptions

1. Travel ban exemptions can be granted on a case-by-case basis for humanitarian purposes or for the fulfilment of judicial processes.

2. Asset freeze exemptions for the fulfilment of some judicial or administrative processes. Certain exemptions available for the fulfilment of contracts or obligations signed prior to the sanctioning of an entity or person.

3. Arms embargo exemptions for Chadian, French or Sudanese forces solely for their use in international patrols or for non-lethal military equipment intended solely for humanitarian or protective use and related technical assistance or training. Supplies intended solely for use by EU or UN personnel are permitted. Supplies of small arms and related equipment are permitted to be supplied to rangers of the Chinko Project and the Bamingui-Bangoran National Park to combat poaching and the smuggling of ivory and arms .

4. The arms embargo no longer applies to the supply to the Central African Republic security forces of weapons with a calibre of 14.5 mm or less, and ammunition and components specially designed for such weapons. The exemption also includes military vehicles which are armed with weapons with a calibre of no greater than 14.5 mm. The provision of rocket-propelled grenades is also permitted. The UN Sanctions Committee must be notified of all such sales.

5. Applications to the UN Sanctions Committee can be made to supply lethal weapons to the security forces of the Central African Republic, not including weapons with a calibre of 14.5 mm or less.

Sanction Name

Council Decision Concerning Restrictive Measures Against The Central African Republic

SANCTIONS

Asset Freeze, Arms Embargo, Travel Ban,

First Imposed

December 23, 2013

Last updated

November 11, 2023

Targets

Asset Freeze and Travel Ban:
• Individuals and entities involved in the civil war which have committed war crimes and other abuses of human rights.
• Persons and entities suspected of financing war efforts through the illicit sale of the country’s natural resources.

Arms Embargo:
• All deliveries of arms and other military equipment and supplies to the Central African Republic are prohibited.
•Restrictive measures do not apply to apply to the supply, sale or transfer of arms and related materiel, and the provision of assistance, advice and training to the CAR security forces, including state civilian law enforcement institutions.
•There is no longer a requirement that the provision of arms is for the Security Sector Reform nor a requirement of pre-notification to the UN Sanctions Committee.

Exemptions

1. Travel ban exemptions can be granted on a case-by-case basis for humanitarian purposes or for the fulfilment of judicial processes.

2. Asset freeze exemptions are offered for the fulfilment of some judicial or administrative processes. Certain exemptions are available to support the fulfilment of contracts or obligations signed prior to the sanctioning of an entity or person.

3. Arms embargo exemptions for Chadian, French or Sudanese forces solely for their use in international patrols or for non-lethal military equipment intended solely for humanitarian or protective use and related technical assistance or training. Supplies intended solely for use by EU or UN personnel are permitted, as is the supply of small arms and related equipment to combat poaching and the smuggling of ivory and arms.

4. The arms embargo no longer applies to the supply to the Central African Republic security forces of weapons with a calibre of 14.5 mm or less, and ammunition and components specially designed for such weapons. The exemption also includes military vehicles which are armed with weapons with a calibre of no greater than 14.5 mm. The provision of rocket-propelled grenades is also permitted.

5. The arms embargo no longer applies to the supply, sale or transfer of arms and related materiel, and the provision of assistance, advice and training to the CAR security forces, including state civilian law enforcement institutions.

6. There is no longer a requirement that the provision of arms is for Security Sector Reform nor a requirement of pre-notification to the UN Sanctions Committee.

Sanction Name

Regulation On Measures Against The Central African Republic

SANCTIONS

Asset Freeze, Arms Embargo, Travel Ban,

First Imposed

March 14, 2014

Last updated

March 15, 2024

Targets

Asset Freeze and Travel Ban:
• Individuals and entities involved in the civil war who have committed war crimes and other abuses of human rights.
• Persons and entities suspected of financing war efforts through the illicit sale of the country’s natural resources.

Arms Embargo:
• All deliveries of arms and other military equipment and supplies to the Central African Republic are prohibited.

Exemptions

1. Travel ban exemptions can be granted on a case-by-case basis for humanitarian purposes or for the fulfilment of judicial processes.

2. Asset freeze exemptions are offered for the fulfilment of some judicial or administrative processes. Certain exemptions are available for the fulfilment of contracts or obligations signed prior to the sanctioning of an entity or person.

3. Arms embargo exemptions for Chadian, French or Sudanese forces solely for their use in international patrols or for non-lethal military equipment intended solely for humanitarian or protective use and related technical assistance or training. Supplies intended solely for use by EU or UN personnel are permitted, as is the supply of small arms and related equipment to combat poaching and the smuggling of ivory and arms.

Marking the 75th Anniversary of the Universal Declaration of Human Rights, on 8th December 2023 OFAC designated two individuals contributing to ongoing instability in the Central African Republic (“CAR”). Jean-Francis Bozize, a CAR national and son of former CAR President Francois Bozize, has moved weapons and ammunition from neighboring countries into CAR for the Coalition for the Patriots of Change (“CPC”), a rebel group that has recruited child soldiers and perpetrated sexual violence. Mahamat Salleh, a CAR national, is a CPC commander and a former zone commander for the CPC-affiliated group, the Popular Front for the Rebirth of CAR, who has raped girls and forced them into sexual slavery.

Sanction Name

Sanctions against Certain Persons Contributing to the Conflict in the Central African Republic

SANCTIONS

Specially Designated National, Travel Ban,

First Imposed

May 12, 2014

Last updated

December 8, 2023

Targets

Specially Designated National and Travel Ban:
• Individuals and entities involved in the civil war who have committed war crimes and other abuses of human rights.
• Persons and entities suspected of financing war efforts through the illicit sale of the country’s natural resources.

Sanction Name

Central African Republic (Sanctions) (EU Exit) Regulations 2020

SANCTIONS

Asset Freeze, Arms Embargo, Travel Ban,

First Imposed

December 31, 2020

Last updated

February 23, 2024

Targets

Asset Freeze and Travel Ban:
• Individuals and entities involved in the civil war deemed to have committed war crimes and other abuses of human rights.
• Persons and entities suspected of financing war efforts through the illicit sale of the country’s natural resources.

Arms Embargo:
• All deliveries of arms and other military equipment and supplies to the Central African Republic are prohibited.

Exemptions

1. Travel ban exemptions can be granted on a case-by-case basis for humanitarian purposes or for the fulfilment of a judicial process.

2. Asset freeze exemptions are offered for the fulfilment of some judicial or administrative processes. Certain exemptions are available to support the fulfilment of contracts or obligations signed prior to sanctioning of an entity or person.

3. Arms embargo exemptions for Chadian, French or Sudanese forces solely for their use in international patrols or for non-lethal military equipment intended solely for humanitarian or protective use, and related technical assistance or training. Supplies intended solely for use by EU or UN personnel are permitted, as is the supply of small arms and related equipment to combat poaching and the smuggling of ivory and arms.

4. The arms embargo no longer applies to weapons with a calibre of 14.5 mm or less, and ammunition and components specially designed for such weapons, which are supplied to the Central African Republic security forces. The exemption also includes military vehicles which are armed with weapons with a calibre of no greater than 14.5 mm. The provision of rocket-propelled grenades (“RPG”) is also permitted.

Some trade restrictions were put in place on China following the Tiananmen Square protests of 1989. On 20th July 2020 this was extended to Hong Kong after then-US President Donald Trump declared a national emergency in response to restrictions on the territory’s autonomy and freedom of expression imposed under the Hong Kong National Security Law.

Sanction Name

European Council Sanctions Against China

SANCTIONS

Trade Restrictions,

First Imposed

June 27, 1989

Last updated

June 27, 1989

Targets

Trade Restriction:
• Ban on supply of arms or equipment for the suppression of civil society protests.

Exemptions

1. All EU countries are permitted their own interpretations of the ban.

On 12th November 2023 the US government extended the Chinese military companies sanctions programme sanctions for one year.

Sanction Name

Chinese Military Companies Sanctions

First Imposed

November 17, 2020

Last updated

June 1, 2022

Targets

Trade Restriction:
•Prohibits any transaction with an entity deemed to be a “Communist Chinese military company”. The measure includes a ban on transacting in publicly trading securities or derivatives in target companies. 31 Chinese companies were initially targeted; the companies are listed in the annex to the Executive Order. The Secretary of Defense and the Secretary of the Treasury are also permitted to designate companies as Communist Chinese Military Companies, therefore making them subject to the sanctions programme.

Exemptions

1. Divestment from companies named in the order, where the securities or derivatives were purchased prior to the 11th November 2020 was permitted until 11th January 2021.

Sanction Name

Hong-Kong Related Sanctions

SANCTIONS

Specially Designated National,

First Imposed

July 14, 2020

Last updated

December 20, 2021

Targets

Specially Designated National
• Individuals deemed by OFAC to have undermined Hong Kong’s autonomy and restricted the freedom of expression or assembly of the citizens of Hong Kong.

Sanction Name

Export Control Order 2008

First Imposed

December 31, 2020

Last updated

June 7, 2021

Targets

Arms Embargo:
• Lethal weapons, such as machine guns, large-calibre weapons, bombs, torpedoes, rockets and missiles
• Specially designated components of the above and ammunition
• Military aircraft and helicopters, vessels of war, armoured fighting vehicles and other weapons platforms
• Any equipment which might be used for internal repression.

Trade restrictions on Cuba were first introduced by the US in 1960 following the communist revolution. It continues to operate a combination of Specially Designated Nationals and trade restrictions targeting the government. Having been significantly relaxed under President Obama (2009-17), President Trump (2017-2021) oversaw a renewed tightening of measures, which has continued under current President Biden.

Sanction Name

Implementation Of The Cuban Democracy Act

First Imposed

July 4, 1993

Last updated

September 26, 2022

Targets

Specially Designated National:
• Members of the Cuban government.
• Some entities under the control of, or which act on behalf of, the Cuban Military, intelligence and security services.

Trade Restriction and Travel Ban:
• Prohibits direct financial transactions between US citizens and Cuban nationals. This includes so-called “U-Turn transactions”, relating to transactions originating and terminating outside the US, which have been prohibited since September 2019.
• Prohibits travel to Cuba by US citizens.

Exemptions

1. Certain transactions related to Cuban pharmaceuticals, medical research and humanitarian-related services are authorised.

2. Travel to Cuba by US citizens is allowed for a small number of defined purposes.

3. Remittances to Cuban citizens of up to $1,000 per quarter are allowed, although remittances to Cuban officials or Cuban Communist Party members are prohibited. Entities identified as being controlled by the Cuban military are banned from receiving remittances.

Various sanctions programmes and trade embargoes have been put in place to protect human rights in DRC since the former government of Mobuto Sese Seko, which ended in 1997. Current programmes target parties found to have been committing serious human rights abuses or trading illegally in the country’s natural resources during its successive civil wars and subsequent instability.

On 27th June 2023 the UN renewed the sanctions measures relating to the arms embargo, travel ban, asset freeze and other trade restrictions until 1st August 2024.

Sanction Name

UN Security Council Resolution on the DRC

First Imposed

July 28, 2003

Last updated

February 20, 2024

Targets

Asset Freeze and Travel Ban:
• Members of armed groups in the country determined to be disruptive to disarmament or political reintegration and those who have used child soldiers or targeted civilians or peacekeepers.
• Individuals and entities trading in raw materials in order to fund sanctioned groups and individuals.

Arms Embargo:
• All non-state actors.

Exemptions

1. Travel ban exemptions can be granted on a case-by-case basis on humanitarian or medical grounds and to further the objectives of peace and reconciliation in DRC.

2. Asset Freeze exemptions can be granted for certain expenses on a case-by-case basis.

3. Arms supplied following prior notification to the UN Sanctions Committee for use by DRC Government, UN personnel or non-lethal equipment intended solely for humanitarian or protective use is exempt from sanctions.

On 8th December 2023 the sanctions programme was extended until 12th December 2024.

Sanction Name

Restrictive Measures Directed Against Persons Acting In Violation Of The Arms Embargo

SANCTIONS

Asset Freeze, Arms Embargo, Travel Ban,

First Imposed

May 23, 2013

Last updated

December 21, 2023

Targets

Asset Freeze and Travel Ban:
• Members of armed groups in the country determined to be disruptive to disarmament or political reintegration and those who have used child soldiers or targeted civilians or peacekeepers.
• Individuals and entities trading in raw materials in order to fund sanctioned groups and individuals.
• Individuals or entities providing technical or financial assistance in relation to the supply of arms and materiel.
• Individuals responsible for sustaining the armed conflict, instability or insecurity in the DRC, and those providing support to people or entities responsible for sustaining the armed conflict, instability or insecurity in the DRC,
• Individuals inciting violence in connection with the planning, connecting or committing of human rights violations, as well as those exploiting the armed conflict, instability or insecurity in the DRC, including through the illicit exploitation or trade of natural resources, or those associated with people or entities referred to above.

Arms Embargo:
• All non-state actors.

Exemptions

1. Asset freeze exemptions are permitted for basic expenses, the provision of legal and professional services, fees for the routine holding of frozen funds and for the satisfaction of judicial, administrative or arbitral liens or judgments.

Sanction Name

Regulation On Measures Against the Democratic Republic of Congo

SANCTIONS

Asset Freeze, Arms Embargo, Travel Ban,

First Imposed

June 22, 2005

Last updated

March 15, 2024

Targets

Asset Freeze and Travel Ban:
• Members of armed groups in the country determined to be disruptive to disarmament or political reintegration and those who have used child soldiers, targeted civilians or peacekeepers.
• Individuals and entities trading in raw materials in order to fund sanctioned groups and individuals.
• Individuals or entities providing technical or financial assistance in relation to the supply of arms and materiel.

Arms Embargo:
• All non-state actors.

Exemptions

1. Certain transactions are authorised for humanitarian purposes; to protect Swiss interests; to prevent cases of rigor; to respect existing contracts; and to respect judicial, administrative or arbitral judgements.

2. Movement of sanctioned individuals through Switzerland is permitted for humanitarian reasons, for political dialogue concerning the Democratic Republic of Congo, or for the protection of Swiss interests.

Marking the 75th Anniversary of the Universal Declaration of Human Rights, on 8th December 2023 OFAC designated three individuals contributing to ongoing instability in the Democratic Republic of the Congo (DRC). William Yakutumba, the founder, military commander, and political leader of the Mai-Mai Yakutumba militia and the National Coalition of the People for the Sovereignty of Congo (CNPSC), a coalition of several armed groups in South Kivu province, DRC, that attacked civilians and humanitarian actors. Willy Ngoma is the military spokesperson for the March 23 Movement (M23), an armed group that has perpetrated human rights abuses, including killings, attacks, and sexual violence against civilians. Michel Rukunda, a DRC national, is the commander and overall military leader of the armed group Twirwaneho.

Sanction Name

Democratic Republic Of The Congo Sanctions Program

SANCTIONS

Specially Designated National, Arms Embargo,

First Imposed

October 27, 2006

Last updated

December 8, 2023

Targets

Specially Designated National:
• Members of armed groups in the country determined to be disruptive to disarmament or political reintegration and those who have used child soldiers, targeted civilians or peacekeepers.
• Individuals and entities trading in raw materials in order to fund sanctioned groups and individuals.

Arms Embargo:
• All non-state actors.

Exemptions

1. Under interpretive sanctions, property and interests are blocked if they are 50% beneficially owned, individually or in the aggregate, by sanctioned persons

Sanction Name

Democratic Republic of the Congo (Sanctions) (EU Exit) Regulations 2019

SANCTIONS

Asset Freeze, Arms Embargo, Travel Ban,

First Imposed

December 31, 2020

Last updated

February 23, 2024

Targets

Asset Freeze and Travel Ban:
• Members of armed groups in the country determined to be disruptive to disarmament or political reintegration and those who have used child soldiers or targeted civilians or peacekeepers.
• Individuals and entities trading in raw materials in order to fund sanctioned groups and individuals.
• Individuals or entities providing technical or financial assistance in relation to the supply of arms and materiel.

Arms Embargo:
• All non-state actors.

Exemptions

1. Asset freeze exemptions are permitted for basic expenses, the provision of legal and professional services, fees for the routine holding of frozen funds and for the satisfaction of judicial, administrative or arbitral liens or judgments.

In September 2021 President Biden signed into law sanctions aimed at targeting those involved in perpetuating violence in the northern Tigray region, including both government forces and their opponents, primarily the Tigray People’s Liberation Front. To date, the only body sanctioned is the Eritrean military, due to its involvement in the conflict.

Sanction Name

Sanctions With Respect to the Humanitarian and Human Rights Crisis in Ethiopia

First Imposed

September 17, 2021

Last updated

February 8, 2022

Targets

Asset Freeze and Travel Ban:
• Individuals considered to have been complicit in actions that threaten the peace and stability of Ethiopia, including corruption; serious human rights abuses; obstructing humanitarian assistance; targeting civilians or attacking UN or African Union personnel.
• Military or security forces operating in Northern Ethiopia can also be sanctioned, as well as entities, government bodies and political parties that have contributed to the crisis or blocked peace efforts. This includes senior individuals in the Government of Ethiopia, the Government of Eritrea or its ruling People’s Front for Democracy and Justice, the Tigray People’s Liberation Front, the Amhara regional government, or the Amhara regional or irregular forces, on or after 1st November 2020.

Exemptions

1. There are exemptions for humanitarian and other actors operating in Ethiopia including the UN, several arbitration organisations, global development banks and humanitarian organisations.
2. NGOs operating in Ethiopia in the food and medical care sector are exempt from the sanctions, as are organisations promoting democracy and the rule of law, education programmes, health or those engaged in conservation efforts.
3. There are exemptions for those delivering food, seeds, fertilisers and livestock to Ethiopia, as well as exemptions forth delivery of medicine and medical devices.

In January 2024 the European Council adopted a sanctions framework in Guatemala following repeated attempts to nullify the democratic results of the general and presidential elections in Guatemala, which resulted in a clear victory of President-elect Bernardo Arévalo, as attested by the EU Election Observation Mission to Guatemala.

In view of the persistent attempts to nullify the democratic results of the general and presidential elections in Guatemala, which resulted in a clear victory of President-elect Bernardo Arévalo, as attested by the EU Election Observation Mission to Guatemala, the European Council adopted an autonomous framework for restrictive measures in view of the situation in Guatemala on 12th January 2024

Sanction Name

Restrictive Measures in View of the Situation in Guatemala

First Imposed

January 12, 2024

Last updated

February 2, 2024

Targets

Asset Freeze and Travel Ban:
• The measures target those considered responsible for actions that undermine democracy, the rule of law and a peaceful transfer of power in Guatemala, including through persecution or intimidation of public officials, democratically-elected authorities, civil society, media and judicial operators among others, as well as through financial misconduct concerning public funds and the unauthorised export of capital.

Exemptions

1. There are exemptions for the delivery of humanitarian aid.

The UN introduced a sanctions programme and arms embargo on Haiti in October 2022, in response to significant gang violence undermining security in the country. The EU began its own programme in November 2022, with OFSI and SECO introducing their own the following month.

On 21st October 2022 the UN established a sanctions regime targeting Haiti. On 2nd October 2023 the UN extended the regime for a year, but replaced the targeted arms embargo by a territorial arms embargo.

On 8th December 2023 the UN designated four Haitian gang leaders to its sanctions list.

Sanction Name

UN Sanctions on Haiti

First Imposed

October 21, 2022

Last updated

December 8, 2023

Targets

Asset Freeze and Travel Ban:
• Individuals and entities who are responsible for or complicit in actions that threaten the peace, security or stability of Haiti.

Arms Embargo:
•Necessary measures must be taken to prevent the direct or indirect supply, sale or transfer to, or for the benefit of, the individuals and entities designated by the Committee from or through their territories or by their nationals, or using their flag vessels or aircraft of arms and related materiel of all types, including weapons and ammunition, military vehicles and equipment, paramilitary equipment, and spare parts for the aforementioned, and technical assistance, training, financial or other assistance, related to military activities or the provision, maintenance or use of any arms and related material, including the provision of armed mercenary personnel whether or not originating in their territories.

Exemptions

1. Exemptions can be granted to the travel ban on a case-by-case basis on humanitarian grounds, for religious obligations, the fulfilment of judicial processes, or if an exemption would further the objectives of peace and stability in Haiti.
2. Asset freeze exemptions apply to funds, other financial assets or economic resources that have been determined by relevant member states to be necessary to meet basic expenses, including payment for foodstuffs, rent or mortgage, medical treatment, taxes, insurance premiums, and public utility charges or exclusively for the payment of reasonable professional fees and reimbursement of incurred expenses associated with the provision of legal services. Exemptions also apply to necessary extraordinary expenses or the payment of judicial, administrative or arbitral liens or judgments, provided that the relevant lien or judgment was entered into prior to the date of the present resolution, and is not for the benefit of a designated person or entity.
3. The arms embargo does not apply to the supply, sale, or transfer of small arms, light weapons, or ammunition to the UN or a UN-authorised mission or to a security unit that ooperates under the command of the Government of Haiti, intended to be used by or in coordination with those entities and intended solely to further the objectives of peace and stability in Haiti. It also does not apply to other supplies, sale, or transfer of small arms, light weapons, and ammunition to Haiti as approved in advance by the UN Committee establishe dpursuant to resolution 2653 (2022) to further the objectives of peeace and stability in Haiti.

Sanction Name

Restrictive Measures In View Of The Situation In Haiti

SANCTIONS

Asset Freeze, Travel Ban, Arms Embargo,

First Imposed

November 25, 2022

Last updated

January 15, 2024

Targets

Asset Freeze and Travel Ban:
• Persons designated by the Sanctions Committee as responsible for or complicit in, or having engaged in, directly or indirectly, actions that threaten the peace, stability and security of Haiti.

Arms Embargo:
It is prohibited to:
• Provide technical assistance, training or other assistance, including the provision of armed mercenary personnel, related to military activities or the provision, maintenance or use of any arms and related materiel, directly or indirectly to any person or entity designated by the Sanctions Committee.
• Provide financing or financial assistance related to military activities, including in particular grants, loans and export credit insurance, as well as insurance and reinsurance for any sale, supply, transfer or export of arms and related materiel, or for the provision of related technical or other assistance, directly or indirectly to any designated person or entity.

Exemptions

1. The EU does not oblige Member States to refuse its own nationals entry into its territory.
2.Exemptions can be granted to the travel ban on a case-by-case basis on humanitarian grounds, including for religious obligations, for the fulfilment of a judicial process, or if an exemption would further the objectives of peace and stability in Haiti.
3. Asset freeze sanctions will not apply to funds and economic resources which the relevant Member State has determined to be necessary for basic expenses, including payment for food, rent, mortgages, medical treatment, taxes, insurance premiums and public utility charges.
4.Exemptions apply for the payment of reasonable professional fees and reimbursement of expenses associated with the provision of legal services or fees and service charges, as well as for the payment of fees or service charges for routine holding or maintenance of frozen funds, other financial assets and economic resources. Exemptions also apply to funds which are deemed to be necessary for extraordinary expenses approved by the Sanctions Committee, deemed to be the subject of a judicial, administrative or arbitral lien or judgement, or in the case that a payment was due under a contract entered prior to the designation of a person or entity, provided that the relevant Member State has determined that the payment is not directly or indirectly received by a person or entity.

Sanction Name

Regulation on Measures against Haiti

SANCTIONS

Asset Freeze, Travel Ban, Arms Embargo, ,

First Imposed

December 16, 2022

Last updated

December 8, 2023

Targets

Asset Freeze and Travel Ban:
• Persons designated by the Sanctions Committee as responsible for or complicit in, or having engaged in, directly or indirectly, actions that threaten the peace, stability and security of Haiti.

Arms Embargo:
It is prohibited to:
• Sell, supply, export or transit military capital goods of all kinds, including arms and ammunition, military vehicles and equipment, paramilitary equipment, as well as their accessories and spare parts, to any entities designated by the Sanctions Committee.
• Provide services of any kind, including financial services, brokerage services, technical training and the granting of financial means related to the sale, supply, export, transit, manufacture , the maintenance or use of military equipment of any kind or related to military activities, including the provision of armed mercenaries, to any entities designated by the Sanctions Committee.

Exemptions

1. SECO may , in exceptional circumstances, authorise payments from frozen accounts, transfers of frozen capital assets and the release of frozen economic resources in order to, prevent cases of hardship, to honour existing contracts, or to honour debts pursuant to an existing judicial, administrative or arbitral measure or decision.
2. The State Secretariat for Migration can grant exemptions to the travel ban if the entry or transit through Switzerland is necessary for the purposes of legal proceedings, or in accordance with the decisions of the relevant committee of the UN Security Council.

On 11th July 2023 the UK Export Control Joint Unit amended the Export Control Order 2008, thus extending transit control and the requirement of a licence for the transit of all military goods destined for Haiti, including light weapons.

Sanction Name

The Haiti (Sanctions) Regulations 2022

SANCTIONS

Asset Freeze, Travel Ban, Arms Embargo,

First Imposed

December 28, 2022

Last updated

December 11, 2023

Targets

Asset Freeze and Travel Ban:
Persons designated by the Sanctions Committee as responsible for or complicit in, or having engaged in, directly or indirectly, actions that threaten the peace, stability and security of Haiti.

Arms Embargo:
It is prohibited to:
• Trade in military goods and military technology, where the trade is with, or benefits, a designated person.
• Provide technical assistance, training or other assistance, including the provision of armed mercenary personnel, related to military activities or the provision, maintenance or use of any arms and related materiel, directly or indirectly to any person or entity designated by the Sanctions Committee.
• Provide financing or financial assistance related to military activities, including in particular grants, loans and export credit insurance, as well as insurance and reinsurance for any sale, supply, transfer or export of arms and related materiel, or for the provision of related technical or other assistance, directly or indirectly to any designated person or entity.

Exemptions

1. in relation to Treasury licences, a designated person can apply for a licence allowing funds to be released or made available in order to pay for basic needs, such as food.
2. The prohibitions are not contravened by a person making funds or economic resources available which are necessary to ensure the timely delivery of urgently needed humanitarian assistance, or to support other activities that support basic human needs, in Haiti, by the United Nations, its specialised agencies or programmes, humanitarian organisations having observer status with the United Nations General Assembly that provide humanitarian assistance, and their implementing partners, including bilaterally or multilaterally funded non-governmental organisations participating in the United Nations Humanitarian Response Plan for Haiti.

Sanctions have been imposed against Iran by the US since the 1970s, designating the country an international sponsor of terrorism. Since 2011 the EU and US have also imposed programmes targeting individuals involved in political repression in the country and, alongside the UN, its alleged nuclear weapons programme. The UN and EU have relaxed nuclear-related sanctions against Iran under the Joint Collective Plan of Action (“JCPOA”) since 2015. The US, formerly a participant in the JCPOA, has renounced the programme and re-imposed wide-ranging sanctions and trade restrictions against Iran in 2018.

Sanction Name

UN Sanctions for Iran

First Imposed

July 20, 2015

Last updated

January 23, 2016

Targets

Asset Freeze, Arms Embargo and Trade Restrictions:
• Ban on testing or launching missiles capable of carrying a nuclear warhead.

Exemptions

1. Trade (including arms) and technical assistance are permitted on a case-by-case basis provided the UN Security Council has decided in advance to permit such an activity.

On 11th December 2023 the EU designated six individuals and five entities allegedly involved in Iran’s development and production of unmanned aerial vehicles (“UAV”) used in the war in Ukraine.

Sanction Name

Restrictive Measures Against Certain Entities In View Of The Situation In Iran

SANCTIONS

Asset Freeze,

First Imposed

April 14, 2011

Last updated

September 15, 2023

Targets

Asset Freeze:
• Persons complicit in or responsible for directing human rights violations in the repression of peaceful demonstrators and other civil society actors during the widespread anti-government protests in 2011 or responsible for human rights abuses linked to this repression.
• Individuals and organisations complicit in or responsible for directing human rights violations following the death of Mahsa Amini and the violent response by Iranian security forces to consequent protests.

Exemptions

1. Exemptions can be granted on a case-by-case basis on humanitarian grounds or to support the attendance of inter-governmental meetings.

Sanction Name

Restrictive Measures Against Iran And Repealing Regulation

SANCTIONS

Asset Freeze, Arms Embargo, Trade Restrictions,

First Imposed

February 27, 2007

Last updated

October 18, 2023

Targets

Asset Freeze, Arms Embargo and Trade Restrictions:
• Ban on testing or launching missiles capable of carrying a nuclear warhead.
• Persons and entities involved in nuclear or ballistic missile activities and persons and entities providing support to the Iranian Government in this area.

Exemptions

1. An arms embargo is in force related to nuclear activities and missile technology.
2. Asset freeze exemptions are also permitted for basic expenses, the provision of legal and professional services, fees for the holding of frozen funds and for the satisfaction of judicial, administrative or arbitral liens or judgments.

The current sanctions programme is set to expire on 26th July 2024.

Sanction Name

Restrictive measures in view of Iran’s military support of Russia’s war of aggression against Ukraine

SANCTIONS

Asset Freeze, Travel Ban, Trade Restrictions,

First Imposed

July 20, 2023

Last updated

December 11, 2023

Targets

Asset Freeze, Travel Ban:
• Persons and entities responsible for, or involved in, Iran’s UAV programme. EU persons and entities are also forbidden from making funds available to those listed.

Trade Restrictions:
• Ban on the export of components used in the manufacturing of UAVs.

Exemptions

1. Exemptions can be granted on a case-by-case basis for the delivery of humanitarian aid.

Sanction Name

Regulation on Sanctions Against Iran

SANCTIONS

Asset Freeze, Arms Embargo, Trade Restrictions,

First Imposed

February 14, 2007

Last updated

March 15, 2024

Targets

Asset Freeze and Trade Restrictions:
• Entities involved in nuclear or ballistic missile activities. This programme includes extensive restrictions on trade with Iran, including the provision of arms, dual use goods and other commodities such as diamonds, as well as the provision of services to certain strategic sectors, including the oil and gas sector. There are also prohibitions on the provision of goods, technology and software for launch systems and services, defence equipment and goods that could be used for internal repression, and on equipment and technology relating to inspection software and corresponding services.

Arms Embargo:
• A complete arms embargo is in place as well as an authorisation requirement for nuclear goods. There is also an authorisation requirement for the establishment of joint ventures with Iranian entities involved in the nuclear programme.

Exemptions

1. There are arms embargo exemptions relating to armoured vehicles and other equipment necessary to protect Swiss diplomatic and consular staff in Iran. Exemptions can also be granted for non-lethal military equipment for humanitarian and protective purposes as well as for hunting and sporting weapons.

2. Asset freeze exemptions may be granted to prevent cases of rigor; respect existing contracts; respect credits due under existing judicial, administrative or arbitral judgments; for Iranian diplomatic missions or consular posts; for the implementation of the JCPOA; or to protect Swiss interests.

On 29th January 2024 OFAC and OFSI took joint action against a network of individuals that targeted Iranian dissidents and opposition activists for assassination at the direction of the Iranian regime. The network is led by Iranian narcotics trafficker Naji Ibrahim Sharifi-Zindashti and operates at the behest of Iran’s Ministry of Intelligence and Security (“MOIS”). On 31st January 2024 OFAC sanctioned three entities and one individual located in Lebanon and Turkey for providing critical financial support to an Iranian Islamic Revolutionary Guard Corps-Qods Force (“RGC-QF”) and Hizballah financial network.

On 2nd February 2024 OFAC sanctioned six officials in the Iranian Islamic Revolutionary Guard Corps Cyber-Electronic Command (IRGC-CEC), an Iranian government organization responsible for a series of malicious cyber activities against critical infrastructure in the United States and other countries. OFAC also sanctioned a key procurement network of prolific suppliers of materials and sensitive technology for Iran’s ballistic missile and Unmanned Aerial Vehicle (UAV) programs, including the Shahed-series UAV produced by Iran’s Shahed Aviation Industries Research Center (SAIRC). The four Iran- and Hong Kong-based entities designated have allegedly operated as covert procurement entities for OFAC designated Hamed Dehghan and Pishtazan Kavosh Gostar Boshra (PKGB), who are actively engaged in supporting multiple Iranian military organisations, including the Islamic Revolutionary Guard Corps (IRGC). Additionally, OFAC designated a Hong Kong-based front company involved in the sale of hundreds of millions of dollars’ worth of Iranian commodities for the benefit of the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF).

On 14th February 2024 OFAC sanctioned a procurement network comprising three individuals and four entities responsible for facilitating the illegal export of goods and technology from over two dozen US companies to end-users in Iran, including the Central Bank of Iran, which is designated for its role in providing financial support to the Islamic Revolutionary Guard Corps-Qods Force (“IRGC-QF”) and Hizballah.

On 27th February 2024 OFAC and OFSI took joint action against theIRGC-QF, Mohammad Reza Falahzadeh, as well as a Houthi group member. OFAC also designated the owner and operator of a vessel used to ship Iranian commodities that were sold to support both the Houthis and the IRGC-QF. The action followed the recent US Department of State designation of Ansarallah (commonly known as the Houthis) as a Specially Designated Global Terrorist as a result of their ongoing attacks on international maritime commerce in the Red Sea and Gulf of Aden. The same day OFAC sanctioned two companies registered in Hong Kong and the Marshall Islands that own and operate a vessel, the Panama-flagged Kohana, shipping over $100 million in Iranian commodities to businesses in China on behalf of Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL). MODAFL continues to facilitate the delivery of Iranian weapons to Russia in support of its war in Ukraine and to Iranian-aligned militia groups in the Middle East.

On 20th March 2024 OFAC targeted three procurement networks –– based in Iran, Türkiye, Oman, and Germany –– that have supported Iran’s ballistic missile, nuclear, and defense programs. These networks have procured carbon fiber, epoxy resins, and other missile-applicable goods for Iran’s Islamic Revolutionary Guard Corps Aerospace Force Self Sufficiency Jihad Organization (IRGC ASF SSJO), Ministry of Defense and Armed Forces Logistics (MODAFL), other U.S.-designated entities in Iran’s defense industrial base, and Iran Centrifuge Technology Company (TESA), which is linked to the Atomic Energy Organization of Iran (AEOI).

Sanction Name

OFAC Sanctions Against Iran

SANCTIONS

Specially Designated National, Arms Embargo, Trade Restrictions,

First Imposed

November 14, 1979

Last updated

March 20, 2024

Targets

Specially Designated National and Arms Embargo:
• The Government of Iran and Iranian state-controlled entities, including but not limited to the National Iranian Oil Company, the Naftiran Intertrade Company and the Central Bank of Iran, as well as any entity owned or controlled by, or operating on behalf of these entities. The Supreme Leader of Iran and other state officials appointed by the Supreme Leader are also personally subject to sanctions.
• There is also a prohibition on the provision of financial assistance or technological support for the acquisition of US dollar banknotes by the Government of Iran; Iran’s trade in gold or precious metals; the direct or indirect sale, supply or transfer to or from Iran of graphite or raw or semi-finished metals for integrating industrial processes; significant transactions related to the purchase or sale of Iranian Rials, or the maintenance of significant funds or accounts outside of Iran denominated in Rials; the purchase, subscription to, or facilitation of the issuance of Iranian sovereign debt; and Iran’s automotive sector.
• On 27th September 2022 OFAC designated Iran’s Morality Police and seven senior leaders of Iran’s security organisations following the death of Mahsa Amini in custody after she was detained for allegedly wearing a hijab incorrectly. In October OFAC designated three entities and 21 people, including seven senior leaders within Iran’s government and security apparatus for the shutdown of Iran’s internet access and the continued violence against peaceful protestors in the wake of the death of Mahsa Amini.

Trade Restrictions:
• There are extensive trade prohibitions, including a general ban on imports from Iran and on the direct or indirect export of goods, technology and services to the country. There are also sanctions on individuals and entities active in the iron, steel, aluminium and copper sectors along with trade restrictions on these goods. In addition, certain Iranian government organisations or government-controlled organisations remain sanctioned. Certain US state legislatures also retain their own official embargoes or sanctions programmes against certain Iranian entities.

Exemptions

1. General Licences authorise the following: the re-exportation of certain civil aircraft on a temporary sojourn by a non-US person and related transactions; certain education services, certain services in support of sporting activities involving the US and Iran; certain services in support of NGO activities in Iran; certain services; software and hardware involved in personal communications; certain medical devices and the export or re-export of replacement parts for such devices; the export or re-export of food items; transactions related to consular funds transfers and the transportation of human remains; the export of certain services and software over the internet; and transactions involving Iran performed by US citizens employed by six international organisations. There are also exemptions for online educational courses and educational software.

2. There are also certain exemptions for the Iranian oil sector. Authorisations have been granted for the construction of a gas pipeline between Azerbaijan and Turkey; projects which provide Turkey and Europe energy security and independence from Russia and Iran; and production sharing contracts with governments of countries other than Iran agreed before August 2012.

3. On 24th August 2021 OFAC issued General Licence M-1, authorizing the export to Iran of certain graduate level educational services and software.

4. On 23rd September 2022, OFAC issued General License D-2, concerning the authorisation of software and hardware services used for communications. This measure was a response to the Iranian government interrupting internet access to prevent streaming of crackdowns on protests in the wake of the death of Mahsa Amini.

Links 1

Iranian Assets Control Regulations
Iranian Transactions and Sanctions Regulations
Iranian Financial Sanctions Regulations
Iranian Human Rights Abuses Sanctions Regulations
Executive Order 12170 - Blocking Iranian Government Property (Effective 14/11/1979)
Executive Order 12205 - Prohibiting Certain Transactions With Iran (Effective 17/04/1980)
Executive Order 12211 - Prohibiting Certain Transactions With Iran (Effective17/04/1980)
Executive Order 12276 - Direction Relating to Establishment of Escrow Accounts (Effective 23/01/1981)
Executive Order 12277 - Direction To Transfer Iranian Government Assets (Effective 23/01/1981)
Executive Order 12278 - Direction To Transfer Iranian Government Assets Overseas (Effective 23/01/1981)
Executive Order 12279 - Direction To Transfer Iranian Govt. Assets Held By Domestic Banks (Effective 23/01/1981)
Executive Order 12280 - Direction To Transfer Iranian Government Financial Assets Held By Non-Banking Institutions (Effective 23/01/1981)
Executive Order 12281 - Direction To Transfer Certain Iranian Government Assets (Effective 23/01/1981)
Executive Order 12282 - Revocation of Prohibitions Against Transactions Involving Iran (Effective 23/01/1981)
Executive Order 12283 - Non-Prosecution of Claims of Hostages and for Actions at the United States Embassy and Elsewhere (Effective 23/01/1981)
Executive Order 12284 - Restrictions on the Transfer of Property of the Former Shah of Iran (Effective 23/01/1981)
Executive Order 12294 - Suspension of Litigation Against Iran (Effective 26/02/1981)
Executive Order 12613 - Prohibiting Imports From Iran (Effective 29/10/1987)
Executive Order 12957 - Prohibiting Certain Transactions With Respect to the Development of Iranian Petroleum Resources (Effective 16/03/1995)
Executive Order 12959 - Prohibiting Certain Transactions With Respect to Iran (Effective 07/05/1995)
Executive Order 13059 - Prohibiting Certain Transactions With Respect to Iran (Effective 20/08/1997)
Executive Order 13553 - Blocking Property of Certain Persons With Respect to Serious Human Rights Abuses By The Government of Iran and Taking Certain Other Actions (Effective 29/09/2010)
Executive Order 13599 - Blocking Property of the Government of Iran and Iranian Financial Institutions​ (Effective 06/02/2012)
Executive Order 13606 - Blocking the Property and Suspending Entry Into the United States of Certain Persons With Respect to Grave Human Rights Abuses by the Governments of Iran and Syria via Information Technology​ (Effective 23/04/2012)
Executive Order 13608​ - Prohibiting Certain Transactions With and Suspending Entry Into the United States of Foreign Sanctions Evaders With Respect to Iran and Syria (Effective 01/05/2012)
Executive Order 13846 - Reimposing Certain Sanctions With Respect To Iran
Executive Order 13871 - Imposing Sanctions with Respect to the Iron, Steel, Aluminum, and Copper Sectors of Iran
Executive Order 13876 - Imposing Sanctions with Respect to Iran
Executive Order 13902​​ - Imposing Sanctions With Respect to Additional Sectors of Iran
Executive Order 13949 - Blocking Property of Certain Persons with Respect to the Conventional Arms Activities of Iran
General License - Authorizing the Exportation or Reexportation of Food Items
General License - Authorizing the Exportation or Reexportation of Replacement Parts for Certain Medical Devices- Authorizing the Exportation or Reexportation of Replacement Parts for Certain Medical Devices
General License​ - Related to Consular Funds Transfers and to the Transportation of Human Remains
General License Related to Personal Communication Services - Exportation of certain services and software over the interne
General License 2 - Authorizing U.S. persons who are employees or contractors of six international organizations to perform transactions for the conduct of the official business of those organizations in or involving Iran
General License 8A - Authorizing Certain Humanitarian Trade Transactions Involving the Central Bank of Iran or the National Iranian Oil Company
General License D-2 - General License with Respect to Certain Services, Software, and Hardware Incident to Communications
General License E - Authorizing Certain Services in Support of Nongovernmental Organizations’ Activities in Iran
General License F - Authorizing Certain Services in Support of Professional and Amateur Sports Activities and Exchanges Involving the United States and Iran​
General License G - Certain Academic Exchanges and the Exportation or Importation of Certain Educational Services Authorized
General License J-1 - Authorizing the Reexportation of Certain Civil Aircraft to Iran on Temporary Sojourn and Related Transactions (Amended 12/15/2016)
General License L - Authorizing Certain Transactions Involving Iranian Financial Institutions Blocked Pursuant to Executive Order 13902
General License M-2 - Authorizing the Exportation of Certain Graduate Level Educational Services and Software
General License N-2 - Authorizing Certain Activities to Respond to the Coronavirus Disease 2019 (COVID-19)
General License O - Authorizing Wind-Down and Limited Safety and Environmental Transactions Involving Certain Vessels
List of Medical Devices Requiring Specific Authorization
Iran Ballistic Missile Procurement Advisory (18/10/2023)
Guidance to Industry on Iran's UAV-Related Activities (09/06/2023)
Guidance to Address Illicit Shipping and Sanctions Evasion Practices​​​ (14/05/2020)

Sanction Name

CAATSA Sanctions Against Iran

SANCTIONS

Specially Designated National,

First Imposed

August 2, 2017

Last updated

December 7, 2021

Targets

Specially Designated National:
• CAATSA has imposed additional sanctions against officials, agents, or affiliates of Iran’s Islamic Revolutionary Guard Corps, although these designations have been included under the Counter Terrorism sanctions programme.

Exemptions

1. General Licences authorise the following: the re-exportation of certain civil aircraft on a temporary sojourn by a non-US person and related transactions; certain education services, certain services in support of sporting activities involving the US and Iran; certain services in support of NGO activities in Iran; certain services; software and hardware involved in personal communications; certain medical devices and the export or re-export of replacement parts for such devices; the export or re-export of food items; transactions related to consular funds transfers and the transportation of human remains; the export of certain services and software over the internet; and transactions involving Iran performed by US citizens employed by six international organisations.

2. There are also certain exemptions for the Iranian oil sector. Authorisations have been granted for the construction of a gas pipeline between Azerbaijan and Turkey; that which provides Turkey and Europe energy security and independence from Russia and Iran; and production sharing contracts with governments of countries other than Iran agreed before August 2012.

On 14th December 2023 OFSI published the Iran Sanctions Regulations, revoking and replacing the Iran Sanctions (Human Rights) Regulations 2019. Persons previously designated under the Iran (Human Rights) regime are now designated under the Iran regime.

On 14th December 2023 OFAC and the UK took joint action against Iran’s Islamic Revolutioonary Guard Corps – Qods Force (“IRGC-QF”), Hamas, and Palestinian Islamic Jihad (“PIJ”). The UK designated eight individuals, including the head of the IRGC-QF and individuals linked to Iran’s support for Hamas and PIJ, whilst OFAC designated an IRGC-QF official involved in support to Hamas.

On 29th January 2024 OFSI and OFAC took joint action against a network of individuals that targeted Iranian dissidents and opposition activists for assassination at the direction of the Iranian regime. The network is led by Iranian narcotics trafficker Naji Ibrahim Sharifi-Zindashti and operates at the behest of Iran’s Ministry of Intelligence and Security (“MOIS”)

On 27th February 2024 OFSI and OFAC took joint action against the IRGC-QF, Mohammad Reza Falahzadeh, as well as a Houthi group member.

Sanction Name

UK sanctions relating to Iran

SANCTIONS

Asset Freeze,

First Imposed

December 14, 2023

Last updated

February 27, 2024

Targets

Asset Freeze:
• Persons complicit in or responsible for directing human rights violations in the repression of peaceful demonstrators and other civil society actors during the widespread anti-government protests in 2011 or responsible for human rights abuses linked to this repression.
• Persons or entities involved in the Iranian regime’s activities undermining peace, stability and security in the Middle East and internationally; the use and spread of weapons or weapons technologies from Iran; the Iranian undermining of democracy, respect for the rule of law and good governance; and other hostile activities towards the UK and its allies from the Iranian regime, including threats to its people, property or security.

Exemptions

1. Exemptions can be granted on a case-by-case basis on humanitarian grounds or to support attendance of inter-governmental meetings.

Sanction Name

UK sanctions relating to Iran (nuclear weapons)

SANCTIONS

Asset Freeze, Arms Embargo, Trade Restrictions,

First Imposed

December 31, 2020

Last updated

February 27, 2024

Targets

Asset Freeze, Arms Embargo and Trade Restrictions:
• Ban on testing or launching missiles capable of carrying a nuclear warhead.
• Persons and entities involved in nuclear or ballistic missile activities and persons and entities providing support to the Iranian Government in this area.

Exemptions

1. As UN above, with an arms embargo relating to nuclear activity and missile technology.

2. Asset freeze exemptions are also permitted for basic expenses, the provision of legal and professional services, fees for the holding of frozen funds and for the satisfaction of judicial, administrative or arbitral liens or judgments.

The US, UN and EU currently operate sanctions programmes covering Iraq, targeting individuals deemed to have illicitly enriched themselves during the Presidency of Saddam Hussein, who was deposed in a US-led invasion in 2003, and imposing embargoes on the sale of arms to non-state actors in the country. A US programme also explicitly sanctions individuals and entities engaged in violence against the Iraqi government and peacekeeping forces which support it.

On 5th October 2023 the UN Iraq Sanctions Committee removed Walid Hamid al-Tikriti, the former governor off Basra and member of Saddam Hussein’s administration, from its sanctions list.

Sanction Name

UN Security Council Regulations Against Iraq

First Imposed

November 24, 2003

Last updated

October 5, 2023

Targets

Asset Freeze and Arms Embargo:
• All funds belonging to Saddam Hussein, senior members of his administration and their immediate family members. A ban on the sale of arms to end users in Iraq, with the exception of international peacekeeping forces and the Iraqi government.

Exemptions

1. The Government of Iraq is exempt from the arms embargo, although prohibitions on nuclear, chemical and biological weapons as well as on ballistic missiles with a range greater than 150km still apply.

Sanction Name

Council Common Position on Iraq

SANCTIONS

Asset Freeze, Arms Embargo,

First Imposed

July 7, 2003

Last updated

October 13, 2023

Targets

Asset Freeze and Arms Embargo:
• All funds belonging to Saddam Hussein, senior members of his administration and their immediate family members. A ban on the sale of arms to end users in Iraq, except to international peacekeeping forces and the Iraqi government.

Exemptions

1. All petroleum, petroleum products and natural gas exported by Iraq, as well as payments for such goods, are exempt from sanctions in order to promote the economic reconstruction of Iraq and the restructuring of its debt.

2. The Government of Iraq is exempt from the arms embargo.

On 5th October 2023 following actions by the UN, SECO removed Walid Hamid al-Tikriti, the former governor off Basra and member of Saddam Hussein’s administration, from its sanctions list.

Sanction Name

Order Establishing Economic Measures Against The Republic Of Iraq

SANCTIONS

Asset Freeze, Arms Embargo, Trade Restrictions,

First Imposed

May 22, 2003

Last updated

October 5, 2023

Targets

Asset Freeze, Arms Embargo and Trade Restrictions:
• Individuals and entities associated with the former government of Saddam Hussein. This includes financial sanctions and a ban on trading arms and stolen cultural objects.

Exemptions

1. All petroleum, petroleum products and natural gas exported by Iraq, as well as payments for such goods, are exempt from sanctions in order to promote the economic reconstruction of Iraq and the restructuring of its debt.

2. The Government of Iraq is exempt from the arms embargo.

Sanction Name

The Iraq Stabilization and Insurgency Sanctions Regulations

SANCTIONS

Specially Designated National, Trade Restrictions,

First Imposed

August 28, 2003

Last updated

August 23, 2023

Targets

Specially Designated National:
• Individuals and entities associated with the former government of Saddam Hussein and any parties determined to be committing acts of violence which threaten the peace, stability and economic reconstruction of Iraq following the US-led invasion of 2003.

Trade Restrictions:
• Prohibition on the possession or trade in Iraqi cultural property or other items of archaeological, historical, cultural or religious importance deemed to have been illegally removed from the Iraq National Museum, the National Library, and other locations in Iraq since August 1990.

Exemptions

1. Under three General Licences, OFAC authorises all transactions involving 10 state bodies as well as the transfer of claims that were booked in the US, as of 23rd May 2003, against the Iraqi Government for unpaid loans and other debts.

Links 1

Iraq Sanctions Overview
Iraq Stabilization and Insurgency Sanctions Regulations
Removal of the Iraqi Sanctions Regulations (13/09/2010)
Executive Order 13290 - Confiscating and Vesting Certain Iraqi Property (20/03/2003)
Executive Order 13303 - Protecting the Development Fund for Iraq and Certain Other Property in Which Iraq Has an Interest (22/05/2003)
Executive Order 13315 - Blocking Property of the Former Iraqi Regime, Its Senior Officials and Their Family Members, and Taking Certain Other Actions (29/08/2003)
Executive Order 13350 - Termination of Emergency Declared in Executive Order 12722 With Respect to Iraq and Modification of Executive Order 13290, Executive Order 13303, and Executive Order 13315 (30/07/2004)
Executive Order 13364 - Modifying the Protection Granted to the Development Fund for Iraq (29/11/2004)
Executive Order13438 - Blocking Property of Certain Persons Who Threaten Stabilization Efforts in Iraq (17/07/2007)
Executive Order 13668 - Ending Immunities Granted to the Development Fund for Iraq and Certain Other Iraqi Property and Interests in Property Pursuant to Executive Order 13303, as Amended (27/05/2014)
General License 1 / 13315 - On or after 29/08/2003, all transactions with state bodies, corporations, or agencies of the former Iraqi regime that are otherwise prohibited by Executive Order 13315, are permitted. (30/08/2003)
General License 6 - Section 575.534 Transfers of certain blocked claims by US financial institutions (30/09/2003)
General License - Section 575.533 Certain new transactions now authorized (26/03/2004)

On 6th October 2023 following actions by the UN, SECO removed Walid Hamid al-Tikriti, the former governor off Basra and member of Saddam Hussein’s administration, from its sanctions list.

Sanction Name

Iraq (Sanctions) (EU Exit) Regulations 2020

SANCTIONS

Asset Freeze, Arms Embargo,

First Imposed

December 31, 2020

Last updated

October 6, 2023

Targets

Asset Freeze and Arms Embargo:
• All funds belonging to Saddam Hussein, senior members of his administration and their immediate family members. A ban on the sale of arms to end users in Iraq, except international peacekeeping forces and the Iraqi government.

Exemptions

1. All petroleum, petroleum products and natural gas exported by Iraq, as well as payments for such goods, are exempt from sanctions in order to promote the economic reconstruction of Iraq and the restructuring of its debt.

2. The Government of Iraq is exempt from the arms embargo.

Two programmes are currently in place with regard to Lebanon. In 2005, following the assassination of Prime Minister Rafiq Hariri, the UN put in place measures penalising those responsible and seeking to oblige the Government of Syria to co-operate with its independent investigation. New measures were imposed in 2006 following the Israeli invasion, specifically targeting the provision of arms to paramilitary groups in the country.

Sanction Name

UN Security Council Regulations Against Lebanon

First Imposed

October 31, 2005

Last updated

March 27, 2007

Targets

Asset Freeze, Arms Embargo and Travel Ban:
• Individuals suspected of involvement in the assassination of Prime Minister Rafiq Hariri.
• Requires Syrian cooperation with the investigation by the UN’s International Independent Investigation Commission into the assassination of Rafiq Hariri.

On 20th July 2023 the EU extended its Lebanon sanctions regime until 31st July 2024.

Sanction Name

Restrictive Measures In Respect Of Lebanon

SANCTIONS

Asset Freeze, Arms Embargo, Travel Ban,

First Imposed

September 25, 2006

Last updated

November 29, 2023

Targets

Asset Freeze, Arms Embargo and Travel Ban:
• Since the Israeli invasion of Lebanon in 2006 there has also been a prohibition on the supply of arms or related services to any entity in the country without the permission of the Government of Lebanon or international peacekeeping forces.

Sanction Name

Restrictive Measures In Connection With The Assassination of Rafik Hariri

SANCTIONS

Asset Freeze,

First Imposed

December 14, 2005

Last updated

February 16, 2023

Targets

Asset Freeze:
• Individuals suspected of involvement in the assassination of Prime Minister Rafiq Hariri.

Exemptions

1. Asset freeze exemptions are permitted for basic expenses, the provision of legal and professional services and fees for the holding of frozen funds.

Sanction Name

Ordinance on Measures Concerning Lebanon

SANCTIONS

Arms Embargo,

First Imposed

August 11, 2006

Last updated

January 1, 2022

Targets

Arms Embargo:
•Since the Israeli invasion of Lebanon in 2006 there has also been a prohibition on the supply of arms or related services to any entity in the country without the permission of the Government of Lebanon or international peacekeeping forces.

Exemptions

1. The Lebanese Government can approve the supply, sale and transit of arms otherwise sanctioned. Arms embargo exemptions also apply to the temporary export of protective clothing for use by media, humanitarian, UN, EU or Swiss personnel.

Sanction Name

Order On Measures Against Certain Persons In Connection With The Assassination Of Rafik Hariri

SANCTIONS

Asset Freeze, Travel Ban,

First Imposed

December 21, 2005

Last updated

March 15, 2024

Targets

Asset Freeze and Travel Ban:
• Individuals suspected of involvement in the assassination of Prime Minister Rafiq Hariri.

Exemptions

1. Travel ban exemptions may be granted on a case-by case basis to protect Swiss interests or to prevent cases of rigor.

Sanction Name

Lebanon Sanctions Program

SANCTIONS

Specially Designated National,

First Imposed

August 1, 2007

Last updated

August 10, 2023

Targets

Specially Designated National:
• Entities engaged in violence to undermine Lebanese government institutions, contribute to the breakdown of the rule of law in the country, reassert Syrian influence or threaten US policy. The sanctions were introduced during the violent struggle between Lebanese security forces and militant Islamist group Fatah Al Islam in 2006.

Sanction Name

UK Sanctions Relating to Lebanon

SANCTIONS

Asset Freeze, Arms Embargo, Travel Ban,

First Imposed

December 31, 2020

Last updated

December 31, 2020

Targets

Asset Freeze, Arms Embargo and Travel Ban:
• Since the Israeli invasion of Lebanon in 2006 there has been a prohibition on the supply of arms or related services to any entity in the country without the permission of the Government of Lebanon or international peacekeeping forces.

Sanction Name

UK sanctions relating to Lebanon (Assassination of Rafiq Hariri and others)

SANCTIONS

Asset Freeze,

First Imposed

December 31, 2020

Last updated

December 31, 2020

Targets

Asset Freeze:
• Individuals suspected of involvement in the assassination of Prime Minister Rafiq Hariri.

Exemptions

1. Asset freeze exemptions are permitted for basic expenses, the provision of legal and professional services and fees for the holding of frozen funds.

Sanctions programmes targeting Libya began with the country’s 2011 civil war, which saw extensive human rights abuses committed under the government of then-head of state Muammar Gaddafi. Since Gaddafi’s removal programmes remain in place targeting individuals involved in offences during the conflict and preventing the misappropriation of frozen government assets.

On 2nd June 2023 the UN Security Council extended its Libya Sanctions Program until 2nd June 2024.

On 29th November 2023 the UN granted a humanitarian travel exemption, valid for six months, to two sanctioned individuals. The same day, the UN amended five entries to the Libya sanctions list.

On 31st January 2024 the UN removed the travel ban on Safia Farkash Al-Barassi, who was granted a six-month humanitarian travel exemption in November 2023. She is still subject to an asset freeze.

Sanction Name

United Nations Security Council Regulations Against Libya

First Imposed

February 26, 2011

Last updated

January 31, 2024

Targets

Arms Embargo and Trade Restrictions:
• Controls on the export of arms or related material to Libya, including a ban on the provision of such items to any recipient apart from the Libyan government.
• Measures against the unlicensed sale of Libyan crude oil and vessels determined to be transporting such.

Asset Freeze and Travel Ban:
• Officials of the former government of the late Muammar Gaddafi who have been implicated in violence against civilians, members of armed groups involved in attacks on infrastructure or foreign missions and the financial supporters of such groups.

Exemptions

1. Arms supplied for use by the Libyan Government; non-lethal equipment intended solely for humanitarian or protective use; or small arms and related material for certain actors is exempt from sanctions, following prior notification to the UN Sanctions Committee.

2. Travel ban exemptions are also in place for travel on humanitarian grounds, the fulfilment of judicial processes or to advance peace and stability in Libya.

3. There is also an exemption on frozen assets with regards to judicial, administrative or arbitral liens or judgments as well as on interests, earnings and payments due under contracts, agreements or obligations entered into prior to the listing of a sanctioned party or for humanitarian purposes.

4. The provision of bunkering services to designated vessels is authorised if it is necessary for humanitarian purposes as is the entry into Libyan ports in the case of emergency.

Sanction Name

Council Regulation Concerning Restrictive Measures In View Of The Situation In Libya

SANCTIONS

Asset Freeze, Arms Embargo, Trade Restrictions,

First Imposed

March 3, 2011

Last updated

February 28, 2024

Targets

Asset Freeze, Arms Embargo and Trade Restrictions:
• Individuals deemed to be posing a risk to the country’s transition to peacetime government following the conclusion of its 2011 civil war, especially those associated with the government of the late former Head of State Muammar Gaddafi or those benefiting from embezzled state funds.

• The programme includes trade restrictions to support these aims, including a ban on the export to Libya of arms or related materiel to any recipients except the government or UN peacekeepers and a prohibition on the loading, transportation or discharge of petroleum products illicitly exported or attempted to be exported from Libya.

• Some restrictions aimed at combating the trade in illegally exported crude oil and restricting the use of economic resources previously controlled by the Gaddafi government. The programme also prohibits the importation of arms from Libya.

Exemptions

1. Exemptions can be granted on a case-by-case basis on humanitarian grounds or to facilitate the attendance of inter-governmental meetings.

2. Asset freeze exemptions are also permitted for basic expenses, the provision of legal and professional services, fees for the holding of frozen funds and for the satisfaction of judicial, administrative or arbitral liens or judgments.

Sanction Name

Order Establishing Measures Against Libya

SANCTIONS

Asset Freeze, Arms Embargo, Travel Ban,

First Imposed

March 30, 2011

Last updated

March 15, 2024

Targets

Asset Freeze, Arms Embargo and Travel Ban:
• The family of the late Muammar Gaddafi, senior officials in his government and any individuals deemed to be responsible for or complicit in human rights abuses during the 2011 Libyan Civil War or to have materially assisted in these abuses. This includes an embargo on the sale of arms to such parties or the purchase of arms from Libya.

Exemptions

1. Non-lethal equipment intended solely for humanitarian or protective use and hunting or sporting weapons are exempt.

2. Asset freeze exemptions apply to prevent cases of rigor, in respect of existing contracts, to respect credits due under existing judicial, administrative or arbitral judgments, for humanitarian purposes, to finance economic reconstruction or to protect Swiss interests.

3. Travel ban exemptions may be granted on humanitarian grounds or for the attendance of international conferences, participation in political dialogue concerning Libya or if the protection of Swiss interests requires it.

Sanction Name

Regulations Against Certain Transactions Related to Libya

SANCTIONS

Specially Designated National, Travel Ban,

First Imposed

February 25, 2011

Last updated

October 17, 2022

Targets

Specially Designated National and Travel Ban:
• The family of the late Muammar Gaddafi, senior officials in his government and any individuals deemed to be responsible for or complicit in human rights abuses during the Libyan Civil War, or who have been engaged in actions or policies that threaten the peace in Libya, have resulted in the misappropriation of Libyan state assets or threaten Libyan state financial institutions or the Libyan National Oil Company.

Exemptions

1. Through eight General Licences, OFAC authorises all transactions with the Government of Libya, the Transitional National Council of Libya and 21 state agencies. Transactions involving Qatar Petroleum or Vitol relating to oil, gas and petroleum products exported from Libya are authorised, while US persons are authorised to continue operating investment funds in which the Government of Libya has both a non-controlling and minority interest.

Sanction Name

Libya (Sanctions) (EU Exit) Regulations 2020

SANCTIONS

Asset Freeze, Arms Embargo, Trade Restrictions,

First Imposed

December 31, 2020

Last updated

November 30, 2023

Targets

Asset Freeze, Arms Embargo and Trade Restrictions:
• Individuals deemed to pose a risk to the country’s transition to peacetime government following the conclusion of its 2011 civil war, especially those associated with the government of the late former Head of State Muammar Gaddafi or those benefiting from embezzled state funds.

• The programme includes trade restrictions to support these aims, including a ban on the export to Libya of arms or related materiel to any recipients except the government or UN peacekeepers and a prohibition on the loading, transportation or discharge of petroleum products illicitly exported or attempted to be exported from Libya.

• Some restrictions aimed at combating the trade in illegally exported crude oil and restricting the use of economic resources previously controlled by the Gaddafi government. The programme also prohibits the importation of arms from Libya.

Exemptions

1. Exemptions can be granted on a case-by-case basis on humanitarian grounds or associated with the attendance of inter-governmental meetings.

2. Asset freeze exemptions are also permitted for basic expenses, the provision of legal and professional services, fees for the holding of frozen funds and for the satisfaction of judicial, administrative or arbitral liens or judgments.

Sanctions against Mali were first imposed in 2017 and target parties involved in unrest in the north of the country, which threatens the implementation of a 2015 peace agreement which ended the country’s civil war. On 30th August 2023 the UN ended its sanctions in Mali after Russia vetoed a renewal of the regime, but the EU, OFAC, OFSI, and SECO continued their restrictions on the country.

On 11th December 2023 the EU renewed its Mali sanctions regime until 14th December 2024.

Sanction Name

Restrictive Measures In View Of The Situation In Mali

First Imposed

September 28, 2017

Last updated

January 4, 2024

Targets

Travel Ban and Asset Freeze:
• Individuals who have threatened peace and stability in Mali and those who have obstructed or violated the 2015 Agreement on Peace and Reconciliation, as well as those who finance and assist sanctions targets. Also includes those who have organised and participated in attacks on government, French and UN forces in the country. Targets those who have committed human rights abuses as well as those who have blocked humanitarian efforts. Recruiters of child soldiers are also included.

Exemptions

1. There is an exemption on frozen assets with regards to judicial, administrative or arbitral liens or judgments as well as for humanitarian purposes.

2. Exemptions on frozen assets and travel bans can be granted on a case-by-case basis to further peace and national reconciliation in Mali

Sanction Name

Regulation on measures against Mali

SANCTIONS

Asset Freeze, Travel Ban,

First Imposed

November 22, 2017

Last updated

September 1, 2023

Targets

Travel Ban and Asset Freeze:
• Individuals who have threatened peace and stability in Mali and those who have obstructed or violated the 2015 Agreement on Peace and Reconciliation, as well as those who finance and assist sanctions targets. Also includes those who have organised and participated in attacks on government, French and UN forces in the country. Targets those who have committed human rights abuses as well as those who have blocked humanitarian efforts. Recruiters of child soldiers are also included.

Exemptions

1. Asset freeze exemptions apply to prevent cases of rigor, in respect of existing contracts, to respect credits due under existing judicial, administrative or arbitral judgments, or to promote regional peace and stability.

2. Travel ban exemptions may be granted if necessary for the purpose of judicial proceedings.

Sanction Name

Blocking Property and Suspending Entry of Certain Persons
Contributing to the Situation in Mali

SANCTIONS

Asset Freeze, Travel Ban,

First Imposed

July 26, 2019

Last updated

August 4, 2023

Targets

Travel Ban and Asset Freeze:
• Individuals who have threatened peace and stability in Mali and those who have obstructed or violated the 2015 Agreement on Peace and Reconciliation, as well as those who finance and assist sanctions targets. Also includes those who have organised and participated in attacks on government, French and UN forces in the country. Targets those who have committed human rights abuses as well as those who have blocked humanitarian efforts. Recruiters of child soldiers are also included. Persons deemed to have been involved in corruption are also targeted.

Sanction Name

Mali (Sanctions) (EU Exit) Regulations 2020

SANCTIONS

Asset Freeze, Travel Ban,

First Imposed

December 31, 2020

Last updated

September 6, 2023

Targets

Travel Ban and Asset Freeze:
• Individuals who have threatened peace and stability in Mali and those who have obstructed or violated the 2015 Agreement on Peace and Reconciliation, as well as those who finance and assist sanctions targets. Also includes those who have organised and participated in attacks on government, French and UN forces in the country. Targets those who have committed human rights abuses as well as those who have blocked humanitarian efforts. Recruiters of child soldiers are also included.

Exemptions

1. There is an exemption on frozen assets with regards to judicial, administrative or arbitral liens or judgments as well as for humanitarian purposes.

2. Exemptions on frozen assets and travel bans can be granted on a case-by-case basis to further peace and national reconciliation in Mali

The Moldovan sanctions programme specifically concerns the conduct of the government of the breakaway government of Transnistria, which has had de facto independence since the dissolution of the USSR in 1991.

On 27th October 2023 the EU renewed its Moldova sanctions regime for one year until 31st October 2024.

On 22nd February 2024 the European Council imposed sanctions on six individuals and one entity responsible for actions aimed at detabilising the independence of Moldova. Those sanctioned include the Association of People with Epaulettes “Scutul Poporului”, a parliamentary organisation and its leader, Chiril Guzun, who allegedly attends protests and uses violence to destabilise the national government; Dmitry Milyutin, the Deputy Head of the Russian Federal Security Service’s Department of Operational Intelligence, responsible for Russia’s covert operations in the Transnistrian region of Moldova; Arina Corșicova, the executive of several communications media trusts in Moldova which have allegedly disseminated false information about the war in Ukraine; Dumitru Chitoroagă, the administrator of a media trust which allegedly spreads false claims about the Moldovan government and expresses support for Ilan Shor; Maria Albot, who leads one of Ilan Shor’s foundations and was allegedly involved in the “Bank Fraud” case that affected the stability of Moldova; and Victor Petrov, the leader of the People’s Union of Gagauzia, a pro-Russian socio-political movement allegedly receiving backing from Ilan Shor.

Sanction Name

Restrictive Measures Against The Republic Of Moldova

First Imposed

September 28, 2010

Last updated

February 22, 2024

Targets

Travel Ban:
• Those involved in designing or implementing the campaign of intimidation and closure against Latin-script schools in the Transdniestria region of Moldova.

Exemptions

1. Exemptions can be granted on a case-by-case basis on humanitarian grounds or for the attendance of inter-governmental meetings.

On 28th June 2023 the Federal Council, acting at the request of the Moldovan government, adopted the measures imposed on the country by the European Union on 28th April 2023 and 30th May 2023. These measures included asset freeze on the assets and economic resources which are the property or under direct or indirect control of designated persons and entities, and of companies and entities that are owned or controlled by designated persons or entities. The measures also included a prohibition on the entry into and transit through Switzerland for all designated persons.

Sanction Name

Regulation on measures concerning Moldova

SANCTIONS

Asset Freeze, Travel Ban,

First Imposed

June 28, 2023

Last updated

March 5, 2024

Targets

Asset Freeze:
• Assets and economic resources which are the property or under the control -direct or indirect – of designated persons and entities, of persons and entities acting on behalf of designated persons or entities, and of companies and entities that are owned or controlled by designated persons or entities.

Travel Ban:
Entry into Switzerland and transit through Switzerland are prohibited for all designated persons.

Exemptions

1. Exemptions can be granted to prevent cases of hardship, to honour existing contracts, to honour debts pursuant to an existing judicial, administrative or arbitral measure or decision, to allow official diplomatic or consular activities, to allow activity of international organisations allowed immunity in international law, or to safeguard Swiss interests.
2. The State Secretariat for Migration may grant exemptions to the travel ban if there are proven humanitarian grounds, if the person travels to attend international conferences or to take part in a political dialogue concerning Moldova, or to safeguard Swiss interests.

International sanctions programmes targeting Myanmar have been in place since 2003, when they were imposed following a violent crackdown on opposition in the country. A US programme was discontinued in 2016 as the country began to liberalise under Aung San Suu Kyi from 2011. As state-backed ethnic violence against the country’s Rohingya minority has increased since 2018, the US has begun to impose sanctions against Burmese individual under its Global Magnitsky programme.

In 2021 the EU and the US introduced new designations targeting individuals deemed to be connected to the country’s February 2021 military coup.

Sanction Name

Restrictive Measures In Respect Of Myanmar/Burma

First Imposed

April 26, 2010

Last updated

December 11, 2023

Targets

Travel Ban and Asset Freeze:
•On 21st February 2022 the EU imposed sanctions on 22 persons in Myanmar, including government ministers and senior armed forces members, as well as four entities, including state-owned energy company Myanmar Oil and Gas Enterprise.

Arms Embargo:
• Prohibition on the sale of arms or related materiel to the Myanmar military junta or its key officials.

Exemptions

1. The provision of technical assistance and financing for non-lethal military equipment intended solely for humanitarian purposes or protective use is allowed. The provision of the same, including protective clothing, is also permitted for UN personnel, representatives of the media and humanitarian and development workers.

Sanction Name

Regulation on measures against Myanmar

SANCTIONS

Arms Embargo, Trade Restrictions,

First Imposed

October 2, 2000

Last updated

December 21, 2023

Targets

Arms Embargo:
• A ban on the sale and transit of arms and goods that could be used for internal repression to individuals linked to political repression and human rights abuses under the country’s ruling military junta.

Trade Restrictions:
• A ban on the sale, supply, export or transit to Myanmar of technology or software that could be used to intercept or monitor communications. A ban is also in place on technology destined for military purposes and on the provision of services, including financial assistance, relating to the supply of such technology.

Exemptions

1. Non-lethal equipment intended solely for humanitarian or protective use; assets for crisis management operations of the UN, EU or Switzerland; demining equipment; and protective clothing for use by media, humanitarian, UN, EU or Swiss personnel are exempt.

On 31st January 2024, marking the three-year anniversary of the military coup in Myanmar, OFAC designated two entities closely associated with Myanmar’s military regime that maintain relationships with Myanma Economic Holdings Public Company Limited (“MEHL”), which was designated by OFAC on 25th March 2021, as well as four individuals who are closely related to the regime through their business relationships and activities. OFAC also issued General License 6 authorising the wind down of transactions involving one of the designated entities – the Shwe Byain Phyu Group of Companies.

On 10th February 2024 the US extended Executive Order 14014 with respect to the situation in Myanmar for a further year until 10th February 2025.

Sanction Name

Burma-Related Sanctions Program

SANCTIONS

,

First Imposed

February 11, 2021

Last updated

February 10, 2024

Targets

Specially Designated National:
• Targeted at those who “played a leading role in the overthrow of Burma’s democratically elected government” in the coup on 1st February 2021.

Exemptions

On 25th March 2021 OFAC issued 4 General Licences authorising the following exemptions to its Burma Sanctions Program:
– Official Business of the United States Government
– Official Activities of Certain International Organizations and Other International Entities
– Certain Transactions in Support of Nongovernmental Organizations’ Activities
– Authorizing the Wind Down of Transactions Involving Myanmar Economic Corporation Ltd and Myanmar Economic Holdings Public Company Ltd

Sanction Name

Myanmar (Sanctions) Regulations 2021

SANCTIONS

Travel Ban,

First Imposed

December 31, 2020

Last updated

February 1, 2024

Targets

Asset Freeze:
• Those involved in undermining democracy, the role of law or good government in Myanmar, the repression of the civil population, the obstruction of proper investigation or the committing of human rights abuses. The asset freeze has been extended to holding companies owned by the country’s military and other state owned entities.

Exemptions

1. Exemptions can be granted on a case-by-case basis on humanitarian grounds or to support the attendance of inter-governmental meetings.

OFAC has operated a sanctions programme against the Nicaraguan government of Daniel Ortega since 2018. The programme was first imposed in response to a violent crackdown ordered by the government against protestors.

On 9th October 2023 the EU extended its Nicaragua sanctions program until 15th October 2024.

Sanction Name

Targeted restrictive measures in view of the situation in Nicaragua

SANCTIONS

Asset Freeze, Travel Ban,

First Imposed

October 15, 2019

Last updated

November 29, 2023

Targets

Asset Freeze and Travel Ban:
• Targeted at those responsible for human rights violations or abuses or for the repression of civil society and democratic opposition in Nicaragua, as well as persons and entities whose actions, policies or activities otherwise undermine democracy and the rule of law in Nicaragua.

Exemptions

1. EU member states are permitted to grant exemptions to the sanctions programme for reasons of: payment for basic living needs; payment of legal services and other fees associated with maintaining bank accounts; the fulfilment of contracts signed before the imposition of the sanctions programme; extraordinary exemptions; or for the fulfilment of diplomatic or consular missions.

2. Frozen funds belonging to sanctions targets can be unblocked in order to satisfy enforceable judgements.

3. Funds may be unfrozen by EU member states for humanitarian purposes.

Sanction Name

Regulation on measures against Nicaragua

SANCTIONS

Asset Freeze, Travel Ban,

First Imposed

May 24, 2020

Last updated

October 24, 2023

Targets

Asset Freeze and Travel Ban:
• Targeted at those responsible for human rights violations or abuses or for the repression of civil society and democratic opposition in Nicaragua, as well as persons and entities whose actions, policies or activities otherwise undermine democracy and the rule of law in Nicaragua.

Exemptions

1. SECO may authorise some payments subject to the sanctions programme for: basic living needs; to fulfil existing contracts; for judicial or diplomatic reasons; or to protect Swiss interests.

2. SECO allows for exemptions from the sanctions measures for humanitarian aid, such as medical care, delivering food, and for humanitarian workers.

On 14th March 2024 the US imposed restrictions on the import and export of U.S. origin defense articles and defense services destined for or originating in Nicaragua. The Department of State has amended the International Traffic in Arms Regulations (ITAR) to update the defense trade policy toward Nicaragua. This action was taken in response to concerns regarding continuing brutal repression by Ortega-Murillo authorities against the people of Nicaragua, including recent sham elections on the Caribbean coast populated mainly by Indigenous individuals and Afro-descendants.

On 21st March 2024, OFAC sanctioned Wendy Carolina Morales Urbina, Nicaragua’s Attorney General,for being complicit in the Ortega-Murillo regime’s oppression.

Sanction Name

Special Designations against Certain Persons Contributing to the Situation in Nicaragua

First Imposed

November 27, 2018

Last updated

March 21, 2024

Targets

Specially Designated National:
• Targeted at those deemed to be responsible for serious human rights abuses in Nicaragua, actions or policies that undermine peace or democracy, or any corrupt activity in the country. Officials of the Government of Nicaragua who have served since January 2007 or anyone who has financially assisted any of the above individuals are also sanctioned.

• There are currently six individuals sanctioned under the programme, including Nicaraguan Vice President and First Lady Rosario Maria Murillo De Ortega; and National Security Advisor Nestor Mancada Lau.

Exemptions

1.Exemptions apply to the winding down of transactions involving the Directorate General of Mines (“DGM”) of the Nicaraguan Ministry of Energy and Mines, or any entity in which DGM owns, directly or indirectly, a 50% or greater interest that are prohibited by Nicaragua Sanctions Regulations.

Sanction Name

Targeted restrictive measures in view of the situation in Nicaragua

SANCTIONS

Asset Freeze, Travel Ban,

First Imposed

December 31, 2020

Last updated

November 15, 2021

Targets

Asset Freeze and Travel Ban:
• Targeted at those responsible for human rights violations or abuses or for the repression of civil society and democratic opposition in Nicaragua, as well as persons and entities whose actions, policies or activities otherwise undermine democracy and the rule of law in Nicaragua.

Exemptions

1. Payment for basic living needs; payment for legal services and other fees associated with maintaining bank accounts; the fulfilment of contracts that were signed before the imposition of the sanctions programme; extraordinary exemptions; or for the fulfilment of diplomatic or consular missions.

2. Frozen funds belonging to sanctions targets can be unblocked in order to satisfy enforceable judgements.

3. Humanitarian purposes.

On 23rd October 2023 the EU set up a Niger sanctions framework following the military coup and the detainment of President Bazoum on 26th July 2023.

On 23rd October 2023 the EU set up a Niger sanctions framework following the military coup and the detainment of President Bazoum on 26th July 2023.

Sanction Name

Restrictive measures in view of the situation in Niger

First Imposed

October 23, 2023

Last updated

October 23, 2023

Targets

Asset Freeze and Travel Ban:
• Targeted at individuals and entities responsible for actions that threaten the peace, stability and security of Niger, undermine the constitutional order, democracy, the rule of law, or constitute serious human rights violations or abuses, or violations of applicable international humanitarian law in Niger.

Exemptions

Authorities may authorise the release of certain frozen funds or economic resources that are:

1. Necessary to satisfy the basic needs of designated natural or legal persons, entities or bodies, and dependent family members of such natural persons, including payments for food, rent or mortgage, medicines and medical treatment, taxes, insurance premiums, and public utility charges.

2. Intended exclusively for the payment of reasonable professional fees or the reimbursement of incurred expenses associated with the provision of legal services.

3. intended exclusively for the payment of fees or service charges for the routine holding or maintenance of frozen funds or economic resources.

4. necessary for extraordinary expenses, provided that the competent authority concerned has notified the competent authorities of the other Member States and the Commission of the grounds on which it considers that a specific authorisation should be granted, at least two weeks prior to the authorisation.

5. to be paid into or from an account of a diplomatic mission or consular post or an international organisation enjoying immunities in accordance with international law, insofar as such payments are intended to be used for official purposes of the diplomatic mission or consular post or international organisation.

6. Necessary to ensure the timely delivery of humanitarian assistance or to support other activities that support basic human needs.

North Korea is the subject of extensive global trade embargoes and sanctions programmes which target its nuclear weapons programmes and extensive human rights abuses committed against its population.

On 23rd March 2023 the UN Security Council extended the mandate of the Panel of Experts until 30th April 2024.

On 15th June 2023 the UN updated its seventh implementation assistance notice “Guidelines for Obtaining Exemptions to Deliver Humanitarian Assistance to the Democratic People’s Republic of Korea”, providing a clear explanation of its humanitarian exemption mechanism, offering guidance on how to submit a humanitarian exemption request, and noting that a case-by-case exemption is required to engage in activity prohibited by any other resolution.

Sanction Name

UN Security Council Regulations Against North Korea

First Imposed

October 14, 2006

Last updated

March 7, 2024

Targets

Asset Freeze and Travel Ban:
• The programme targets any individual or entity found to be aiding the North Korean nuclear weapons programme or those responsible for the launch of an experimental rocket in February 2016.

Arms Embargo:
• Embargo on the delivery of arms or related material or goods which could assist North Korea’s nuclear and ballistic missile programmes.

Trade Restrictions:
• A ban on the delivery to the country of luxury goods, fuel bunkering services or financial services or the importation from North Korea of copper, nickel, silver or zinc
• Prohibition on the leasing, chartering and provision of crew services to North Korea; the registration of a vessel to North Korea; the supply, sale or transfer to North Korea of new helicopters and vessels; and the sale of certain luxury goods.
• Annual cap on the amount of coal exports by North Korea, and a limit for the supply of crude oil and refined petroleum products of 4 million barrels (525,000 tons) and 500,000 barrels respectively from member states per annum. The UN also requires member states to reduce the number of staff at North Korean diplomatic missions and consular posts.

Exemptions

1. There is an exemption to the arms embargo for food or medicine or for the exclusive use for humanitarian or livelihood purposes which will not enable North Korean individuals or entities to generate revenue.

2. An exemption on frozen assets with regard to judicial, administrative or arbitral liens or judgments as well as for North Korean diplomatic missions and financial transactions with DPRK Foreign Trade Bank or the Korea National Insurance Corporation if they are solely for the operation of diplomatic or consular missions or humanitarian assistance activities in coordination with the UN.

3. Correspondent Account approvals are granted for DPRK Foreign Trade Bank with regards to the Russian and Bulgarian Embassies in North Korea, the Russian Consulate in Chongjin and Russian banks Vnesheconombank and Bank Sputnik CJSC.

4. Travel ban exemptions can be authorised on a case-by-case basis for humanitarian purposes.

5. Parties are allowed to supply or be involved in the supply of up to 500,000 barrels of refined petroleum products to North Korea within a 12-month period provided that the UN’s Security Council is notified and the cargoes are not sold to entities associated with sanctioned entities or those associated with DPRK’s nuclear or ballistic missile programmes; and that the cargoes are not used for or to generate revenue for DPRK’s nuclear or ballistic missile programmes.

On 12th December 2022 the EU designated 8 people and 4 entities (including 2 vessels) under its North Korea sanctions regime in response to the continued ballistic-missile-related activities carried out by the country in violation of UN Security Council resolutions.

On 13th November 2023 the EU deleted one entry – O Kuk-ryol (deceased) – and updated 44 entries on its DPRK sanctions list, including ministers, nuclear reseach directors, and bank officers.

Sanction Name

Restrictive Measures Against The Democratic People’s Republic Of Korea

SANCTIONS

Asset Freeze, Arms Embargo, Travel Ban, Trade Restrictions,

First Imposed

December 22, 2010

Last updated

November 15, 2023

Targets

Asset Freeze and Travel Ban:
• The programme targets any individual or entity found to be aiding the North Korean nuclear weapons programme or those responsible for the launch of an experimental rocket in February 2016.
• Asset freeze on government entities linked to Pyongyang’s nuclear or ballistic missile programs. A maximum of €5,000 can be sent from the EU to North Korea in personal remittances.

Arms Embargo:
• The programme also prohibits the procurement from North Korea of arms, related materiel and other goods and technology and imposes restrictions on the procurement of EU aircraft and ships by North Korea.

Trade Restrictions:
• A ban on the export of arms and related material which could support North Korea’s nuclear or ballistic missile programme.
• Embargo on all items (except food or medicine) that could contribute to the development of the operational capabilities of the North Korea’s armed forces and on the importation from North Korea of certain mineral products (including coal, iron, copper, nickel silver, zinc and gold) and exports to North Korea of aviation fuel.
• There is also a ban on manufacturing in the chemical, mining and refining industry, on the provision of computer and related services and on the export of oil to the country.

Exemptions

1. Exemptions can be granted on a case-by-case basis on humanitarian grounds, for the activities of North Korean diplomatic missions or for the attendance of inter-governmental meetings.

2. Asset freeze exemptions are also permitted for basic expenses, the provision of legal and professional services, fees for the holding of frozen funds and for the satisfaction of judicial, administrative or arbitral liens or judgments.

Sanction Name

Order Establishing Measures Against The Democratic People’s Republic Of Korea

SANCTIONS

Asset Freeze, Arms Embargo, Travel Ban, Trade Restrictions,

First Imposed

October 25, 2006

Last updated

March 7, 2024

Targets

Asset Freeze and Travel Ban:
• The programme targets any individual or entity found to be aiding the North Korean nuclear weapons programme or those responsible for the launch of an experimental rocket in February 2016.

Arms Embargo:
• Embargo on the delivery of arms or related material or goods which could assist North Korea’s nuclear and ballistic missile programmes.

Trade Restrictions:
• A ban on the delivery to the country of luxury goods, fuel bunkering services or financial services.
• Prohibition on the leasing, chartering and provision of crew services to North Korea; the registration of a vessel to North Korea; the supply, sale or transfer to North Korea of new helicopters and vessels; and the sale of certain luxury goods.
• An annual cap on the amount of coal exports by North Korea and an embargo on North Korean copper, nickel, silver and zinc. The supply of crude oil and refined petroleum products to North Korea is limited to 4 million barrels (525,000 tons) and 500,000 barrels respectively from member states per annum. The UN also requires member states to reduce the number of staff at North Korean diplomatic missions and consular posts.
• Swiss banks are prohibited from opening and managing branches in North Korea.
• The acquisition, purchase, import, transit and transport of fish and seafood from North Korea, is prohibited, as is the maintenance of existing and the establishment of new joint ventures with North Korean companies or individuals.
• There is also a prohibition against entering into contracts with North Korea regarding the rental or leasing of aircraft and related services. Work permits for North Korean nationals have been revoked.

Exemptions

1. The supply of spare parts for commercial aircraft is exempt from the trade restrictions.

2. Work permits may be issued if they are necessary on humanitarian grounds or necessary for contributions towards denuclearisation.

3. Asset freeze exemptions can be granted to prevent cases of rigor, in respect of existing contracts, to respect credits due under existing judicial, administrative or arbitral judgments, to provide humanitarian aid or to contribute to denuclearisation.

4. From 1st December 2019 humanitarian aid and other goods authorised by the US SC Sanctions Council will be exempt from the sanctions programme.

On 15th February 2024 OFAC amended the North Korea Sanctions Regulations to amend or add general licenses to facilitate certain humanitarian-related and journalistic activities

On 27th March, OFAC sanctioned six individuals and two entities based in Russia, China, and the United Arab Emirates, that generate revenue and facilitate financial transactions for the Democratic People’s Republic of Korea (DPRK). Funds generated through these actors are ultimately funneled to support the DPRK’s weapons of mass destruction (WMD) programs.

Sanction Name

North Korea Sanctions Program

SANCTIONS

Specially Designated National, Arms Embargo, Travel Ban, Trade Restrictions,

First Imposed

June 16, 2000

Last updated

March 27, 2024

Targets

Specially Designated National, Arms Embargo and Travel Ban:
• Sanctions against North Korea are wide ranging. They target the government, including all officials and state-owned entities, the ruling Workers’ Party of Korea and any entities deemed to have provided support to these institutions. The sanctions also cover any entity found to be importing or supporting the importation into North Korea of arms, weapons of mass destruction or related materiel or luxury goods as well as any entities found to be involved in illegal financial activities in support of the government of North Korea or its senior officials. The programme also covers any entities found to be involved in the export of arms from North Korea to the Government of Burma and senior officials of entities involved in this activity.
• The programme also includes the special designation of any individual or entity found to be aiding the North Korean nuclear weapons programme and those responsible for the launch of an experimental rocket in February 2016.

Trade Restrictions:
• All imports into the US from North Korea are prohibited, with the exception of OFAC-designated exemptions. The export of US goods to sanctioned entities in North Korea is prohibited.

Exemptions

1. Certain transactions with the North Korean government and North Korean individuals are authorised by OFAC. US persons are permitted to send and receive, and US-registered financial brokers are authorised to process, transfers of funds for North Korean residents, provided that the funds relate to personal remittances to a value of up to $5,000 and the individuals are not specifically sanctioned. Brokers are similarly allowed to process funds necessary for the operation of non-US third country diplomatic missions to North Korea. US financial institutions that hold blocked accounts are authorised to debit the accounts for normal service charges.

2. OFAC authorises transactions relating to: the receipt and transmission of mail and telecommunications; certain aspects of intellectual property protection; and the provision of and payment for goods for the mission of North Korea to the United Nations. The provision of emergency medical services, as well as of certain legal services to sanctioned entities, is authorised. Requests to land on US soil issued by vessels that have landed in North Korea in the preceding 180 days are also granted in certain emergency circumstances.

3. OFAC allows the activities of certain nongovernmental organisations, including those engaged in building democracy. Organisations engaged in education are no longer authorised.

4. Limited humanitarian transactions are permitted as well as the delivery of medical supplies in order to combat the COVID-19 pandemic.

Sanction Name

CAATSA Sanctions Against North Korea

SANCTIONS

Specially Designated National,

First Imposed

August 2, 2018

Last updated

May 20, 2020

Targets

Specially Designated National:
•CAATSA allows the US to impose sanctions to enforce and implement the UN Security Council`s Sanctions against North Korea, with inclusions regarding human rights abuses by the North Korean Government, goods manufactured with North Korean labour and investigations on cooperation between North Korea and Iran in relation to ballistic missile development.

Exemptions

1. Certain transactions with the North Korean government and North Korean individuals are authorised by OFAC. US persons are permitted to send and receive, and US-registered financial brokers are authorised to process, transfers of funds for North Korean residents, provided that the funds relate to personal remittances of up to $5,000, and the individuals are not specifically sanctioned. Brokers are similarly allowed to process funds necessary for the operation of non-US third country diplomatic missions to North Korea. US financial institutions that hold blocked accounts are also authorised to debit the accounts for normal service charges.
2. OFAC also authorises transactions relating to: the receipt and transmission of mail and telecommunications; certain aspects of intellectual property protection; and provision of and payment for goods for the mission of North Korea to the United Nations. The provision of emergency medical services, as well as of certain legal services to sanctioned entities, is authorised. Requests to land on US soil issued by vessels that have landed in North Korea in the preceding 180 days are also granted in certain emergency circumstances.

3. OFAC allows the activities of certain nongovernmental organisations, including those engaged in building democracy. Organisations engaged in education are no longer authorised.

Sanction Name

Democratic People’s Republic of Korea (Sanctions) (EU Exit) Regulations 2019

SANCTIONS

Asset Freeze, Arms Embargo, Travel Ban, Trade Restrictions,

First Imposed

December 31, 2020

Last updated

March 11, 2024

Targets

Asset Freeze and Travel Ban:
• Any individual or entity found to be aiding the North Korean nuclear weapons programme or those responsible for the launch of an experimental rocket in February 2016.
• Government entities linked to Pyongyang’s nuclear or ballistic missile programs.

Arms Embargo:
• The programme also prohibits the procurement from North Korea of arms, related materiel and other goods and technology and imposes restrictions on the procurement of UK aircraft and ships by North Korea.

Trade Restrictions:
• A ban on the export of arms and related material, which could support North Korea’s nuclear or ballistic missile programme.
• Recent updates extend the embargo against North Korea to cover all items (except food or medicine) that could contribute to the development of the operational capabilities of North Korea’s armed forces and prohibit the importation from North Korea of certain mineral products (including coal, iron, copper, nickel silver, zinc and gold) and exports to North Korea of aviation fuel.
• There is also a ban on manufacturing in the chemical, mining and refining industry, on the provision of computer and related services and on the export of oil to the country.

Exemptions

1. Exemptions can be granted on a case-by-case basis on humanitarian grounds, for the activities of North Korean diplomatic missions or to support the attendance of inter-governmental meetings.

2. Asset freeze exemptions are also permitted for basic expenses, the provision of legal and professional services, fees for the holding of frozen funds and for the satisfaction of judicial, administrative or arbitral liens or judgments.

In view of the 7th October 2023 attacks carried out against Israel, the EU and OFAC imposed targeted sanctions regimes in Paelstinian territories. The EU initiated sanctions against Hamas, the Palestinian Islamic Jihadi, and those who support them on 19th January 2024, and OFAC initiated its West Bank-related sanctions programme on 1st February 2024.

On 19th January 2024 The EU established a sanctions framework targeting individuals and entities who support, facilitate or enable violent actions by Hamas and the Palestinian Islamic Jihad. The EU also designated six individuals for providing financial support to Hamas.

Sanction Name

Restrictive Measures Against Hamas and the Palestinian Islamic Jihad

SANCTIONS

Asset Freeze,

First Imposed

January 19, 2024

Last updated

January 19, 2024

Targets

Asset Freeze
The freezing of funds and economic resources of, and the prohibition to make funds and economic resources available to, certain natural or legal persons, groups, entities and bodies supporting, facilitating or enabling violent actions by or on behalf of Hamas and the Palestinian Islamic Jihad. Individuals and entities are listed for:
• supporting, materially or financially, Hamas, the PIJ, or any other affiliated group;
• participating in the planning, preparation or enabling of violent actions by, in conjunction with, under the name of, on behalf of, or in support of Hamas or PIJ;
• supplying, selling, or transferring arms and related materiel to the two organisations;
• supporting, materially or financially, actions which undermine or threaten the stability or security of Israel in conjunction with Hamas and the PIJ;
• being involved in serious violations of international humanitarian law or human rights law on behalf or in the name of Hamas or PIJ;
• inciting or publicly provoking violent actions of the two organisations;
• providing support to those facilitating or enabling violent action by Hamas and the PIJ.

On 1st February 2024 President Joe Biden signed Executive Order 14115, imposing certain sanctions on persons undermining peace, security, and stability in the West Bank. The Executive Order was signed due to increasingly high levels of extremist settler violence, forced displacement of people and villages, and property destruction in the West Bank and Gaza, Israel, and the broader Middle East region. OFAC subsequently designated four Israeli individuals pursuant to the new Executive Order.

Sanction Name

West Bank-Related Sanctions

First Imposed

February 1, 2024

Last updated

March 14, 2024

Targets

Asset Freeze and Travel Ban:
Individuals and entities, including government bodies, that are responsible for or complicit in, or have directly or indirectly engaged in
• Actions that threaten the peace, security, or stability of the West Bank;
• Planning, ordring, otherwise directing, or participating in specific actions affecting the West Bank, such as an act of violence or threat of violence targeting civilians, efforts to place civilians in fear of violence, property destruction, or seizure and dispossession of property.

Sanctions were first imposed on Guinea in 2010, following a violent suppression of protests against the military government of Dadis Camara. Camara was deposed in December 2009 and subsequently fled the country but measures remain in place.

Sanction Name

Restrictive Measures In Respect Of The Republic Of Guinea

First Imposed

October 25, 2010

Last updated

November 29, 2023

Targets

Asset Freeze and Travel Ban:
• Members of the National Council for Democracy and Development and individuals associated with it who are deemed to be responsible for the violent repression of protests on 28th September 2009 by the then military government of Moussa Dadis Camara.

Exemptions

1. Travel ban exemptions may be granted where travel is justified on the grounds of urgent humanitarian need, or to attend intergovernmental meetings promoting discussions of democracy, human rights and the rule of law in the Republic of Guinea.

Sanction Name

Regulation on measures against Guinea

SANCTIONS

Asset Freeze, Travel Ban,

First Imposed

December 16, 2009

Last updated

March 15, 2024

Targets

Asset Freeze and Travel Ban:
• Those involved in the military crackdown on protests in September 2009.

Exemptions

1. Asset freeze exemptions may be granted to protect Swiss interests or to prevent penalties.

2. Travel ban exemptions may be granted on humanitarian grounds, to attend international conferences, to participate in political dialogue concerning Guinea or for the protection of Swiss interests.

Sanction Name

Guinea (Sanctions) (EU Exit) Regulations 2019

SANCTIONS

Asset Freeze, Travel Ban,

First Imposed

December 31, 2020

Last updated

December 31, 2020

Targets

Asset Freeze and Travel Ban:
• Members of the National Council for Democracy and Development, which ruled Guinea between 2008 and 2010, and individuals associated with it who are deemed to be responsible for the violent repression of protests on 28th September 2009 by the then military government of Moussa Dadis Camara.

Exemptions

1. Travel ban exemptions may be granted where travel is justified on the grounds of urgent humanitarian need, or to attend intergovernmental meetings promoting discussions of democracy, human rights and the rule of law in the Republic of Guinea.

The UN and the EU currently operate sanctions programmes targeting individuals associated with two attempted coups in the country: the 2010 army mutiny and the 2012 failed coup d’état.

Sanction Name

UN Sanctions on Republic of Guinea-Bissau

First Imposed

May 18, 2012

Last updated

February 28, 2018

Targets

Travel Ban:
• Individuals who participated in the April 2012 coup d’état or who are otherwise involved in seeking to undermine national stability.

Exemptions

Travel ban exemptions may be granted on a case-by-case basis by the committee: on the grounds of humanitarian need, including religious obligation; where entry of transit is necessary for the fulfilment of a judicial process; or where the committee determines that an exemption would further the objectives of peace and national reconciliation in Guinea-Bissau and stability in the region.

Sanction Name

Restrictive Measures Against Entities Threatening The Republic Of Guinea-Bissau

SANCTIONS

Asset Freeze, Travel Ban,

First Imposed

May 4, 2012

Last updated

August 5, 2023

Targets

Asset Freeze and Travel Ban:
• Entities seeking to undermine political stability in the country, including:
those who participated in the 1st April 2010 army mutiny in which then Prime Minister Carlos Gomes was briefly placed under house arrest.
those involved in the 12th April 2012 coup d’état which led to the suspension of democratic government until 2014.

Exemptions

1. Exemptions can be granted on a case-by-case basis for humanitarian grounds or to support the attendance of inter-governmental meetings.

Sanction Name

Regulation On Measures Against Guinea-Bissau

SANCTIONS

Asset Freeze, Travel Ban,

First Imposed

June 1, 2012

Last updated

March 15, 2024

Targets

Asset Freeze and Travel Ban:
• Entities seeking to undermine political stability in the country.

Exemptions

1. Asset freeze exemptions may be granted to protect Swiss interests, to prevent cases of rigor, to respect existing contracts or to respect credits due under existing judicial, administrative or arbitral judgments.

2. Travel ban exemptions may be granted on humanitarian grounds, to support the attendance of international conferences, to participate in political dialogue concerning Guinea-Bissau or for the protection of Swiss interests.

Sanction Name

Guinea-Bissau (Sanctions) (EU Exit)

SANCTIONS

Asset Freeze, Travel Ban,

First Imposed

December 31, 2020

Last updated

March 10, 2022

Targets

Asset Freeze and Travel Ban:
• Entities seeking to undermine political stability in the country, including:
those who participated in the 1st April 2010 army mutiny in which then Prime Minister Carlos Gomes was briefly placed under house arrest.
Those involved in the 12th April 2012 coup d’état which led to the suspension of democratic government until 2014.

Exemptions

1. Exemptions can be granted on a case-by-case basis for humanitarian grounds or for the attendance of inter-governmental meetings.

The UN, EU and US initiated sanctions programmes against Russia in the months following the country’s March 2014 annexation of the Ukrainian province of Crimea. Measures were strengthened in subsequent months in response to Russian involvement in civil conflict in Eastern Ukraine, which saw a number of provinces gain de facto independence from Kiev. US measures against Russia were further strengthened in 2016 and 2017 via the Countering America’s Adversaries Through Sanctions Act, which targets supporters of Russian President Vladimir Putin, and legislation seeking to penalise Russian alleged interference in the 2016 US Presidential election.

The sanctions on Russia have been significantly strengthened following Russia’s invasion of Ukraine on 24th February 2022.

Sanction Name

Restrictive Measures In Response To The Illegal Annexation Of Crimea And Sevastopol

First Imposed

June 23, 2014

Last updated

June 21, 2023

Targets

Trade Restrictions:
• Ban on the importation of goods from or investment in assets in Crimea or Sevastopol. Prohibition of the export to Crimea and Sevastopol of goods and technology for use in the sectors of transport, telecommunications, energy, oil, gas, infrastructure and mineral resources or related services, as well as services related to tourism. Prohibition of certain ships from entering ports in Crimea and Sevastopol.

Sanction Name

Restrictive measures in response to the recognition of the non-government controlled areas of the Donetsk and Luhansk oblasts of Ukraine and the ordering of Russian armed forces into those areas.

SANCTIONS

Trade Restrictions,

First Imposed

February 23, 2022

Last updated

February 21, 2024

Targets

Trade Restrictions:
•Prohibit the importation of goods from or investment in assets in the so-called Donetsk People’s Republic (“DNR”) or the Luhansk People’s Republic (“LNR”). Prohibition of the export to the DNR and LNR of goods and technology for use in the sectors of transportation, telecommunications, energy, oil, gas, infrastructure and mineral resources or related services, as well as services related to tourism.

•Prohibit the sale, supply, transfer or export of maritime navigation goods and technology to any person/entity in Russia, for use in Russia, or for the placing on board of a Russian-flagged vessel.

• The terms of measures against Russia to include anything which might contribute to Russia’s military or technological enhancement.

• Prohibitions on the provision of maritime transport, technical services or financial assistance related to the maritime transport of crude oil or petroleum products which originate in or are exported from Russia. Other sanctions include, but are not limited to, import restrictions on Russian products such as cigarettes and precious metals, restrictions on the sale or export of goods used in the aviation sector, amendments to export restrictions on items which may contribute to Russia’s military enhancement, including a prohibition on the sale of civilian firearms, a prohibition on the provision of crypto-asset wallets and a ban on the provision of architectural and engineering services, IT consultancy services and legal advisory services to the government of Russia or legal persons established in Russia. There are also sanctions imposed on individuals and entities deemed to have played a role in the organisation of the sham referenda in the Ukrainian regions of Donetsk and Luhansk.

Exemptions

Certain humanitarian and safety-related exceptions are available relating to the sale, supply, transfer or export of maritime navigation goods and technology to any person/entity in Russia, for use in Russia, or for the placing on board of a Russian-flagged vessel.

On 18th December 2023 the EU adopted the 12th package of Russia sanctions which included a ban from 1st January 2024 on non-industrial natural and synthetic diamonds originating or exported from Russia; a ban on Russia diamonds processed in third countries, including jewellery will be phased in progressively from March 2024 and completed by September 2024; a requirement for EU exporters to contractually prohibit re-exportation to Russia of sensitive goods and technology (such as items used in military systems and aviation goods) when selling to third countries; the designation of 61 individuals and 86 entities inclduing operators in the Russian military and defence sectors; expansion of the list of restricted items; restrictions on imports of goods such as pig iron; import ban on liquefied propane with a 12-month transitional period; and exemptions to import restrictions on personal use items, including hygiene, clothing, and cars; a greater enforcement of anti-circumvention measures; the enforcement of the oil price cap; and an iron and steel import ban.

On 29th January 2024 the European Council renewed for a further six months its restrictive measures in view of Russia’s continued actions in Ukraine, until 31st July 2024.

On 23rd February 2024 the European Council adopted the 13th package of restrictive measures against Russia in view of the second year mark of the Russian invasion of Ukraine. As part of the 13th package the EU imposed restrictive measures on an additional 106 individuals and 88 entities responsible for actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine. The new designations primarily target the military and defence sectors and associated individuals, including those involved in DPRK armament supply to Russia, as well as members of the judiciary, local politicians and people responsible for the illegal deportation and military re-education of Ukrainian children. Some of the entities are located in third countries (India, Sri Lanka, China, Serbia, Kazakhstan, Thailand, and Turkey) and have been involved in the circumvention of trade restrictions, others are Russian entities involved in the development, production and supply of electronic components for Russia’s military and industrial complex.

Sanction Name

Restrictive Measures In View Of Russia’s Actions Destabilising The Situation In Ukraine

SANCTIONS

Arms Embargo, Travel Ban, Trade Restrictions,

First Imposed

July 31, 2014

Last updated

February 23, 2024

Targets

Arms Embargo, Trade Restrictions and Travel Ban:
• Prohibition on the provision of long-term financial or investment services to state-owned Russian financial institutions, the export of arms and related material and on the supply of dual-use goods and technology to military end-users, as well as services, goods and technology related to deep water, Arctic and shale oil prospecting. The procurement from Russia of arms and related materiel is prohibited, and there is also a ban on trading in certain bonds, equities and other financial instruments.

• All Russian Central Bank assets have been frozen and there is a ban on providing any loans or investments or investment services to the Government of Russia and the Central Bank.

• Ban on transactions with the Central Bank of Russia and prohibition of the acceptance of any deposits from Russian nationals if their total value exceeds €100,000.

• Ban on the provision of SWIFT services to Bank Otkritie, Novikombank, Promsvyazbank, Bank Rossiya, Sovcombank, VNESHECONOMBANK, Sberbank, Credit Bank of Moscow, the Russian Agricultural Bank, and VTB Bank. Investment participation or financing of the Russian Direct Investment Fund are also prohibited.

• Trade restrictions which prohibit the importation into the EU of Russian origin coal, wood, cement, fertilisers, seafood and liquor. Access to EU ports is prohibited for Russia-flagged vessels and there are a range of specific export bans on sensitive products such as jet fuel, quantum computers and high-end electronics.

•An import ban on Russian crude oil and petroleum products, export measures on 92 entities and a suspension of the broadcasting of Russian state channels in the EU.

• Prohibited EU vessels from transporting Russian crude oil from 5th December 2022, and petroleum products from 5th February 2023 to third countries. Also prohibited the related provision of technical assistance, brokering services or financing or financial assistance.

• It is prohibited for operators to broadcast or to enable to be broadcast any content by Russian media outlets RT Arabic and Sputnik Arabic through any means of transmission or distribution, including by cable, satellite, internet or IP-TV. Any broadcasting licence or authorisation, transmission and distribution arrangement with these outlets is to be suspended and it is also prohibited to advertise products in any content produced or broadcast by the outlets mentioned above.

• Export bans on critical technology and industrial goods, such as electronics, machine parts, specialised vehicles, and cranes; further restrictions on the export of dual use goods and advanced technology goods, including 47 new electronic components that can be used in Russian weapons systems; export restrictions on specific rare earth materials and thermal cameras; and further restrictions on imports of goods which generate significant revenues for Russia, such as bitumen and synthetic rubber.

•A ban on non-industrial natural and synthetic diamonds originating or exported from Russia. The ban was introduced on 1st Janury 2024, phased in progressively from March 2024, and completed by September 2024.

Exemptions

1. On 30th November 2017 the EU permitted certain operations concerning hydrazine in concentrations of 70% or more, necessary for the ExoMars 2020 joint mission between the European Space Agency and the Roscosmos State Corporation.

2. On 5th December 2022 the European Council set a price cap of $60 per barrel for the purposes of an exemption to the ban on the provision of maritime transport and related services tied to the sale of Russian seaborne oil to third countries. On 5th February 2023 the European Council adopted new price caps for certain oil products: $100 per barrel for oil products traded at a premium to crude oil, such as diesel, and $45 per barrel for oil products traded at a discount to crude oil, such as fuel oil.

3. An emergency clause was introduced in December 2022 necessary for the prevention or mitigation of an event likely to have a serious impact on human health and safety or the environment, regarding sanctions on Russia’s oil sector.

4. Exemptions to import restrictions are in place on personal use items, including hygiene, clothing, and cars.

On 3rd January 2024 the EU designated PJSC Alrosa and its CEO Pavel Marinychev, Russia’s largest diamond producer, accounting for over 90% of Russian diamond production.

Sanction Name

Restrictive Measures In Respect Of Actions Undermining Or Threatening Ukraine

SANCTIONS

Asset Freeze, Travel Ban,

First Imposed

March 17, 2014

Last updated

February 23, 2024

Targets

Asset Freeze and Travel Ban:
• Ukrainian Sovereignty and Security – Those deemed to be responsible for or supporting actions which threaten the security, territorial integrity, sovereignty and independence of Ukraine, or obstruct the work of international organisations there. Also explicitly targets Russian policymakers responsible for the annexation of Crimea and the destabilisation of Eastern Ukraine, or any entities conducting transactions with separatist groups in Ukraine’s Donbass region. The sanctions programme also targets entities in Crimea and Sevastopol which have had their ownership transferred contrary to Ukrainian law and the beneficiaries of such transfers.

• A number of military, political and business figures have been personally sanctioned.

• Export controls and restrictions on the sale of dual-use goods and technology that can contribute to the enhancement of Russia’s defence and security sector, an export ban on aviation and space industry goods, including aircraft engines and their parts, a ban on the direct exports of drone engines to Russia and any third country that can supply drones to Russia, an asset freeze against two additional Russian banks (Credit bank of Moscow and Dalnevostochniy Bank), a full transaction ban on the Russian Regional Development Bank, the suspension of the EU broadcasting licences of four Russian media outlets (NTV/NTV Mir, Rossiya 1, REN TV, and Pervyi Kanal), a ban on the provision of EU advertising, market research and public opinion polling services, a ban on the provision of product testing and technical inspection services to Russia, the prohibition of new investments in Russia’s mining sector (with the exception of certain critical raw material mines and quarries), and a prohibition against EU nationals holding any posts on the governing bodies of any Russian state-owned or controlled legal persons, entities or bodies located in Russia.

Exemptions

1. Exemptions can be granted on a case-by-case basis on humanitarian grounds or for the attendance of inter-governmental meetings.

On 1st February 2024 Switzerland adopted certain measures of the EU’s 12th package of sanctions against Russia, including the ban on Russian diamonds, import controls on various goods, such as iron and LPG, and the ban on Russian nationals from controlling cryptocurrency companies.

Sanction Name

Order Establishing Measures To Prevent The Circumvention Of International Sanctions In Relation To The Situation In Ukraine

SANCTIONS

Asset Freeze, Arms Embargo, Trade Restrictions,

First Imposed

March 6, 2015

Last updated

March 22, 2024

Targets

Asset Freeze:
• Any entities found to be responsible for or complicit in undermining democratic processes or institutions in Ukraine during the country’s ongoing civil conflict, including the assertion of governmental authority over any area of the country without the authorisation of the Government of Ukraine. The assets of the Central Bank of Russia are frozen.

Trade Restrictions:
• Strict controls on investment in Russia and Ukraine, including a prohibition on the provision of loans to companies in Crimea and Sevastopol and on investment in companies and real estate there. The same applies to the so-called Donetsk People’s Republic (“DNR”) and the Luhansk People’s Republic (“LNR”).
• The provision of tourism-related services in the Crimea region is banned and documentation from the Ukrainian authorities is required for the export of goods originating there. Financing relating to the export of goods from Sevastopol and Crimea is prohibited. The same applies to the DNR and LNR.
• There are controls on the issuance of short-term financial instruments to banks and companies in Russia and Ukraine. Financing and finance services to the Russian government and Central Bank of Russia are prohibited.
• Reporting obligations are in place for financial intermediaries and companies providing certain services and technical assistance to listed companies or exporting goods used in prospecting for crude oil in Arctic, deepwater or shale projects.
•On 13th April 2022 SECO announced that it had formally mirrored the latest sanctions package implemented by the EU, the focus of which was a set of new trade restrictions against a number of strategic sectors of the Russian economy, including coal, luxury goods, wood, and cement.

Arms Embargo:
• A ban on the export of dual use and military goods to Russia.
• The importation of military equipment from Russia or Ukraine is banned.

Exemptions

1. There are exemptions for business entered into before the imposition of sanctions in March 2015. Financial instruments with Russian banks which have a maturity exceeding 30 days that were arranged prior to 12th November 2014 are also exempt.

2.SECO may grant exemptions from trade restrictions if goods exported to Crimea and Sevastopol are necessary to prevent serious health or safety hazards, including goods used for the protection of existing infrastructure and the environment.

Sanction Name

Special Designations Certain Persons and Transactions With Respect to the Crimea Region of Ukraine

SANCTIONS

Specially Designated National, Travel Ban, Trade Restrictions,

First Imposed

March 6, 2014

Last updated

April 14, 2023

Targets

Specially Designated National and Travel Ban:
• Any entities found to be responsible for or complicit in undermining democratic processes or institutions in Ukraine during the country’s ongoing civil conflict, including the assertion of governmental authority over any area of the country without the authorisation of the Government of Ukraine.
• The programme extends to any entities found to have misappropriated assets owned by the government or economically significant entities in the country.

Trade Restrictions:
• US entities are prohibited from any new investment in the Crimea region, from importing goods from Crimea or exporting US goods there, or providing financial support for such transactions. The same applies to the so-called Donetsk People’s Republic (“DNR”) and Luhansk People’s Republic (“LNR”).
• The direct or indirect provision of goods, technology or services, except financial services, in support of oil exploration or production in deepwater or Arctic offshore areas or shale oil production projects in Russian-controlled territory is also prohibited. US entities are prohibited from engaging in the construction of the Nord Stream 2 and Turkstream pipeline projects and are banned from selling or leasing vessels to participate in the projects.
•On 21st February 2022 OFAC released Executive Order 14065, which blocked investment and trading with the so-called Donetsk People’s Republic (“DNR”) and the Luhansk People’s Republic (“LNR”). Any property in the US belonging to or controlled by those deemed to have operated in the DNR or LNR, been a leader of forces in the territory or have materially assisted the territories is subject to sanctions.

Exemptions

1. OFAC authorises certain transactions under 21 General Licences. The majority of these relate to transactions necessary to maintain or wind down operations or existing contracts with several Russian and Ukrainian entities. In addition, certain transactions are authorised if they are deemed necessary to divest or transfer debt, equity or other holdings in certain blocked parties; derivative products whose value is linked to an underlying asset that constitutes a prohibited debt under the sanctions programme; and certain transactions conducted by financial institutions. With regard to Crimea, authorisations extend to: certain transactions related to telecommunications and mail; internet-based communications; the operation of personal accounts; non-commercial personal remittances; and the export or re-export of certain agricultural commodities, medicine, medical supplies and replacement parts.

2. Exemptions include the winding down of transactions involving the DNR and LNR, coronavirus exemptions for the DNR and LNR, some telecommunications and communications exemptions, and exemptions for some remittances and for UN, arbitration and humanitarian organisations.

Links 1

Executive Order 13660 - Blocking Property of Certain Persons Contributing to the Situation in Ukraine (06/03/2014)
Executive Order 13661 - Blocking Property of Additional Persons Contributing to the Situation in Ukraine (17/03/2014)
Executive Order 13662 - Blocking Property of Additional Persons Contributing to the Situation in Ukraine (20/03/2014)
Executive Order 13685 - Blocking Property of Certain Persons and Prohibiting Certain Transactions with Respect to the Crimea Region of Ukraine (19/12/2014)
Determination Pursuant to Executive Order 13662 - Financial Services and Energy Sectors
Determination Pursuant to Executive Order 13662 - Defense and Related Materiel Sector
Update to the List of Medical Supplies for Ukraine-/Russia-Related Sanctions
General License 11 - ​Authorizing Certain Transactions With FAU Glavgosekspertiza Rossii (20/12/2016)
General License 18 - Authorizing the Exportation or Reexportation of Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates to Certain Regions of Ukraine and Transactions Related to the Coronavirus Disease 2019 (COVID-19) Pandemic (21/02/2022)
General License 19 - Authorizing Transactions Related to Telecommunications and Mail (21/02/2022)
General License 20 - Official Business of Certain International Organizations and Entities (21/02/2022)
General License 21 - Authorizing Noncommercial, Personal Remittances and the Operation of Accounts (21/02/2022)
General License 22 - Authorizing the Exportation of Certain Services and Software Incident to Internet-Based Communications (21/02/2022)
General License 23 - Certain Transactions in Support of Nongovernmental Organizations’ Activities (11/03/2022)
General License 24 - Transactions Related to the Provision of Maritime Services (18/03/2022)
General License 25 - Journalistic Activities and Establishment of News Bureaus in Certain Regions of Ukraine (24/03/2022)

Sanction Name

CAATSA Sanctions Against Russia

SANCTIONS

Specially Designated National,

First Imposed

August 2, 2017

Last updated

September 15, 2022

Targets

Specially Designated National:
• OFAC can implement CAATSA sanctions against specific parties following a consultation between the Secretary of State, the Secretary of the Treasury and the President. The Secretary of State has drawn up a list of individuals deemed to be senior political figures (Section 241 list) or engaged with the intelligence or defence sectors of the Russian Government, although sanctions have not so far been implemented against them (Section 231 list).
• On 6th April 2018 OFAC sanctioned seven Russian oligarchs and 12 companies they own or control, along with 17 senior Russian government officials, a state-owned Russian weapons trading company and its subsidiary, a Russian bank. These sanctions followed the Treasury’s January 2018 issuance of Section 241 of the CAATSA report to Congress, in which it listed senior Russian political figures and oligarchs, as determined by their proximity to the Russian regime and their estimated wealth.
• CAATSA sanctions are also targeted at parties deemed to be involved in activities of the Russian state that undermine cybersecurity; on persons engaging with the intelligence or defence sectors of the Russian Government; on parties involved in the development of oil pipelines in Russia and those which have invested in Russian state-owned assets. The sanctions also prohibit any transactions in foreign exchange that are subject to US jurisdiction in which the sanctioned party has an interest and also prevent US financial institutions from providing loans totalling $10 million in any 12-month period to sanctioned parties.

On 1st February 2024 the Price Cap Coalition published an Oil Price Cap Compliance and Enforcement Alert, which is directed at both government and industry stakeholders, provides examples of specific evasion methods to improve compliance measures, and provides avenues to report suspected oil price cap breaches to members of the Price Cap Coalition.

On 8th February 2024 OFAC published a determination for prohibitions related to the imports of diamonds of Russian origin and diamonds exports from Russia, as well as a determination for prohibitions related to imports of certain categories of diamonds. On 23rd February 2024 OFAC issued General Licence 83A, authorising certain transactions related to imports of certain categories of fish, seafood, and preparations thereof.

Sanction Name

OFAC Sectoral Sanctions on Russia

SANCTIONS

Trade Restrictions,

First Imposed

March 20, 2014

Last updated

February 23, 2024

Targets

Trade Restrictions:
• Ban on investment, the transfer of technology and certain transactions to entities within the Russian oil and gas, metals, mining, financial services, engineering and defence industries which are listed on the Sectoral Sanctions Identifiers List.

• Ban on the importation into the United States of crude oil; petroleum; petroleum fuels, oils, and products of their distillation; liquefied natural gas; coal; and coal products of Russian Federation origin.

•Prohibition of imports, exports and new investment in Russian-origin fish, seafood, alcoholic beverages, non-industrial diamonds, luxury goods or any other sector to be determined by the Secretary of the Treasury.

•Prohibition of the provision of quantum computing services to Russian entities and imposition of sanctions on any person or entity determined to operate or have operated in that sector of the Russian economy.

Exemptions

General Licenses 25A, 33 and 34, authorise winddown periods in respect of the export of professional services, including management consultancy and public relations management. General License 25A further permits transactions necessary for the receipt or transmission of telecommunications involving the Russian Federation.

General License 55 authorises certain services related to the maritime transport of crude oil originating from the Sakhalin-2 project, provided that the Sakhalin-2 by-product is solely for importation into Japan. General License 56 authorises certain services related to the importation of crude oil into Bulgaria, Croatia, or landlocked EU member states as described in Council Regulation (EU) 2022/879 on 3rd June 2022. General License 57 authorises certain services related to addressing vessel emergencies concerning the health or safety of the crew or environmental protection.

On 5th December 2022 the Secretary of the Treasury announced that the price cap on crude oil of Russian origin will be $60 per barrel, above which service providers are prohibited from supporting shipments of Russian oil to other countries. On 5th February 2023 OFAC introduced price caps of $45 per barrel for discount to crude oil products and $100 per barrel for premium to crude oil products of Russian origin.

General License 8G, authorises certain transactions related to energy, including transactions involving, among other financial institutions, Russia’s State Corporation Bank for Development and Foreign Economic Affairs and Vnesheconombank.

General Licenses 60 and 61 authorise certain transactions related to the wind down and rejection of transactions, the debt or equity of, or derivative contracts, involving certain entities designated by sanctions imposed on the anniversary of the Russian invasion of Ukraine on 24th February 2023.

Links 1

Russian Harmful Foreign Activities Sanctions Regulations
Sectoral Sanctions Identifications List
Executive Order 14039 - Blocking Property with Respect to Certain Russian Energy Export Pipelines (20/08/2021)
Executive Order 14066 - Prohibiting Certain Imports And New Investments With Respect To Continued Russian Federation Efforts To Undermine the Sovereignty And Territorial Integrity Of Ukraine (08/03/2022)
Executive Order 14068 - Prohibiting Certain Imports, Exports, and New Investment with Respect to Continued Russian Federation Aggression (11/03/2022)
Determination Pursuant to Executive Order 14068 (Effective 28/06/2022) - Prohibitions Related to Imports of Gold of Russian Federation Origin
Determination Pursuant to Executive Order 14068 (Effective 22/12/2023) - Prohibitions Related to Imports of Certain Categories of Fish, Seafood, and Preparations Thereof
Determination Pursuant to Executive Order 14068 (Effective 01/03/2024) - Prohibitions Related to Imports of Certain Categories of Diamonds
Determinations Pursuant to Executive Order 14068 (Effective 01/03/2024) - Prohibitions Related to Imports of Diamond Jewelry and Unsorted Diamonds of Russian Federation Origin and Diamond Jewelry and Unsorted Diamonds Exported From the Russian Federation
Executive Order 14071 - Prohibiting New Investment In And Certain Services To The Russian Federation In Response To Continued Russian Federation Aggression (06/04/2022)
Determination Pursuant to Executive Order 14071 (Effective 08/05/2022) - Prohibitions Related to Certain Accounting, Trust and Corporate Formation, and Management Consulting Services
Determination Pursuant to Executive Order 14071 (Effective 15/09/2022) - Prohibitions Related to Certain Quantum Computing Services
Determination Pursuant to Executive Order 14071 (Effective 05/12/2022) - Prohibitions on Certain Services as They Relate to the Maritime Transport of Crude Oil of Russian Federation Origin
Determination Pursuant to Executive Order 14071 (Effective 05/12/2022) - Price Cap on Crude Oil of Russian Federation Origin
Determination Pursuant to Executive Order 14071 (Effective 05/02/2023) - Prohibition on Certain Services as They Relate to the Maritime Transport of Petroleum Products of Russian Federation Origin
Determination Pursuant to Executive Order 14071 (Effective 05/02/ 2023) - Price Cap on Petroleum Products of Russian Federation Origin
Determination Pursuant to Executive Order 14071 (Effective 18/06/2023) - Prohibitions Related to Architecture Services and Engineering Services
Maritime Oil Industry Advisory
Guidance on the Implementation of the Russian Oil Price Cap Policy
Possible Evasion of the Russian Oil Price Cap Alert
Price Cap Coalition Oil Price Cap Compliance and Enforcement Alert
General License 6C - Transactions Related to Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates, the Coronavirus Disease 2019 (COVID-19) Pandemic, or Clinical Trials (17/01/2023)
General License 8H - Authorizing Transactions Related to Energy (25/10/2023)
General License 25C - Authorizing Transactions Related to Telecommunications and Certain Internet-Based Communications (14/07/2022)
General License 31 - Authorizing Certain Transactions Related to Patents, Trademarks, and Copyrights (05/05/2022)
General License 38A - Authorizing Transactions Related to Pension Payments (19/08/2022)
General License 44 - Authorizing the Export or Reexport of Certain Accounting Services to U.S. Individuals Located in the Russian Federation (14/07/2022)
General License 46 - Authorizing Transactions in Support of an Auction Process to Settle Certain Credit Derivative Transactions Prohibited by Executive Order 14071 (22/07/2022)
General License 54A - Authorizing Certain Transactions Involving VEON Ltd. or VEON Holdings B.V. Prohibited by Executive Order 14071 (17/01/2023)
General License 56A - Authorizing Certain Services with Respect to the European Union (03/02/2023)
General License 57A - Authorizing Certain Services Related to Vessel Emergencies (03/02/2023)
General License 65 - Authorizing Transactions Related to Telecommunications and Certain Internet-based Communications Involving MegaFon PAO or Digital Invest Limited Liability Company (12/04/2023)
General License 68 - Authorizing the Wind Down of Transactions Involving Certain Universities and Institutes (19/05/2023)
General License 69 - Authorizing Certain Debt Securities Servicing Transactions Involving International Investment Bank (31/05/2023)
General License 70 - Authorizing the Wind Down of Transactions Involving Joint Stock Company Ural Mining and Metallurgical Company (20/07/2023)
General License 73 - Authorizing Limited Safety and Environmental Transactions Involving Certain Persons or Vessels (12/10/2023)
General License 74 - Authorizing the Wind Down and Rejection of Transactions Involving East-West United Bank (02/11/2023)
General License 77 - Authorizing Limited Safety and Environmental Transactions Involving Certain Persons or Vessels (16/11/2023)
General License 78 - Authorizing Limited Safety and Environmental Transactions Involving Certain Persons or Vessels Blocked on December 1, 2023 (01/12/2023)
General License 79 - Authorizing the Wind Down of Transactions Involving Certain Entities Blocked on December 12, 2023,
General License 80 - Authorizing Certain Transactions Related to Debt or Equity of, or Derivative Contracts Involving, Highland Gold Mining Limited
General License 81 - Authorizing Limited Safety and Environmental Transactions Involving Certain Persons or Vessels Blocked on December 20, 2023
General License 83A - Authorizing Certain Transactions Related to Imports of Certain Categories of Fish, Seafood, and Preparations Thereof

On 8th February 2024 OFAC issued General License 87, authorising limited safety and environmental transactions involving certain designated persons or vessels.

On 23rd February 2024, to mark two years of Russia’s war against Ukraine and in response to the death of opposition politician and anticorruption activist Aleksey Navalny, OFAC sanctioned almost 300 individuals and entities, including targets including the state-owned operator of the Mir National Payment System, NSPK, a major cog in Russia’s financial infrastructure; more than two dozen third-country sanctions evaders in Europe, East Asia, Central Asia, and the Middle East; and hundreds of entities in Russia’s military-industrial base and other key sectors. Together with actions from the US Department of State (“DoS”), this is the largest number of sanctions imposed since Russia’s full-scale invasion of Ukraine. DoS also designated three Government of Russia officials in connection with Navalny’s death; together, OFAC and DoS sanctioned over 500 targets to impose additional costs for Russia’s repression, human rights abuses, and aggression against Ukraine. The Department of Commerce also added more than 90 companies to the Entity List.

OFAC also issued General Licenses 88-90 authorising certain transactions relating to entities and vessels blocked on 23rd February 2024. OFAC issued General Licence 88A authorising the wind down of transactions involving certain entities, General License 89 authorising the wind down and rejection of transactions involving certain financial institutions, and General Licence 90 authorising certain transactions related to debt or equity of, or derivative contracts involving, certain Entities. General Licences 91-93 relate to OFAc’s designation of JSC Sovcomflot, Russia’s state-owned shipping company and fleet operator, which was sanctioned along iwth 14 crude oil tankers as property in which Sovcomflot has an interest, in an attempt to reduce Russia’s revenue from oil sales. Concurrent with the designation of Sovcomflot, OFAC issued General License 92 authorising the offloading of crude oil (or other cargo) from these 14 vessels for a period of 45 days, and General License 93 authorising transactions with all other Sovcomflot-owned vessels at this time. OFAC also issued General Licence 91A authorising limited safety and environmental transactions involving certain blocked persons or vessels. Nothing in these general licenses changes any of the restrictions imposed by the price cap sanctions regime.

On 20th March 2024 OFAC sanctioned two individuals and two entities for services they provided the Government of the Russian Federation in connection with a foreign malign influence campaign, including attempting to impersonate legitimate media outlets.

On 25th March 2024, OFAC sanctioned thirteen entities and two individuals for operating in the financial services and technology sectors of the Russian Federation economy including persons developing or offering services in virtual assets that enable the evasion of U.S. sanctions.

On 2nd April 2024, OFAC deleted three entries linked to VTB Bank Public Joint Stock Company.

Sanction Name

Russian Harmful Foreign Activities Sanctions

SANCTIONS

Trade Restrictions,

First Imposed

April 16, 2021

Last updated

April 2, 2024

Targets

Trade Restrictions:
• US nationals are prohibited from transacting with any Russian person or entity deemed by the US Secretary of the Treasury to have been complicit in malicious cyber-enabled activities, interference in a foreign election, to have undermined democratic processes, or to have engaged in transnational corruption or assassination.

• On 16th April 2021 OFAC issued a directive prohibiting US financial institutions from participating in the primary market for new rouble and non-rouble denominated bonds issued by the Russian Central Bank, National Wealth Fund or Ministry of Finance. The directive further prohibits the lending of rouble or non-rouble dominated funds to the same entities. As of later February 2022, there is also a ban on US entities purchasing Russian government debt on the secondary market.

• On 20th August 2021 President Biden signed Executive Order 14039 titled Blocking Property with Respect to Certain Russian Energy Export Pipelines, which targets entities and individuals involved in the construction of the Nord Stream 2 and Turkstream pipeline projects.

• On 22nd February 2022 OFAC amended Directive 1 of Executive Order 14024, imposing new restrictions on US entities dealing in Russian government debt. The measure is aimed at restricting US entities from participating in the secondary market for debt relating to the Russian Central Bank, National Wealth Fund and the Ministry of Finance. On 2nd March 2022, pursuant to EO 14024, OFAC prohibited all transactions involving the Russian Central Bank, the National Wealth Fund and the Ministry of Finance. On 31st March 2022 OFAC extended the trade restrictions outlined in EO 14024 to the aerospace, electronics and marine sectors of the Russian economy.

• In response to the Russian annexations of Donetsk, Luhansk, Kherson and Zaporizhzhia on 30th September 2022, OFAC announced the imposition of further Russian sanctions on 3rd October 2022, pursuant to Executive Order 14024.

Exemptions

1. Transactions with the Federal State Budgetary Institution Marine Rescue Service unrelated to the Nort Stream 2 and Turkstream Pipeline projects. On 23rd February 2022 OFAC released General License 4, which permitted entities involved in transactions with Nord Stream 2 a wind-down period until 2nd March 2022.

2. On 13th April 2022 OFAC issued Russia-related General License No 26, authorising all transactions necessary to the winding down of relationships with JSC SB Sberbank Kazakhstan or Sberbank Europe AG. This was followed on 20th April 2022 by another General License, No 27, authorising “Certain Transactions in Support of Nongovernmental Organizations’ Activities.”

3. On 25th May 2022 OFAC issued Russia-related General License No 13A, authorising certain administrative transactions prohibited by EO 14024. In May OFAC also issued General Licenses 7A, 25A, 26A, 30, 31, 32, 33, 34, and 35, pertaining to a range of sectors including patents, trademarks and copyrights, transactions with Amsterdam Trade Bank NV, trust services, and credit rating agencies.
4. On 28th June 2022 OFAC issued General Licenses 39, 40, 41, 42, and 43 pertaining to transactions with entities such as State Corporation Rostec, PAO Severstal and Nord Gold PLC, as well as transactions with the Federal Security Service and the export to Russia of goods related to civil aviation and agricultural equipment.

5.On 22nd July 2022 OFAC issued General Licenses 44, 45 and 46 pertaining to the export of accounting services to US individuals in Russia, the winding down of certain financial contracts and the authorisation of certain transactions to settle credit derivative transactions.

6.In August 2022 OFAC issued General Licenses 47, 48, 49 and 50 pertaining to the winding down of transactions and contracts involving certain entities blocked by OFAC sanctions, as well as the closure of individual accounts at financial institutions blocked pursuant to sanctions imposed in Executive Order 14024 with respect to specified harmful foreign activities of the Russian government.

7.On 15th September 2022 OFAC issued General License 51 authorising the winding down of transactions involving Russian developer, manufacturer and supplier of computer equipment, limited liability company group of companies Akvarius, or any entity in which Akvarius owns directly or indirectly a 50% or greater interest.

8. On 17th October 2022 OFAC issued General License 28A, authorising certain transactions involving OOO Transkapitalbank and Afghanistan.

9. In November 2022 OFAC issued General Licenses 8D, 53, and 13C, authorising certain transactions prohibited by Executive Order 14024, such as administrative transactions and transactions for diplomatic missions. OFAC also issued General Licenses 40C and 54, authorising transactions necessary for civil aviation safety and certain transactions related to VEON Ltd. On 22nd November OFAC issued General Licenses 55, 56, and 57, authorising certain transactions related to the newly introduced oil price cap, such as transactions concerning emergencies to the health and safety of the crew or environmental protection.

10. On 15th December 2022 OFAC issued General Licenses 58 and 59, authorising certain transactions involving the divestment or transfer of debt or equity from, and the wind down and rejection of transactions involving PJSC Rosbank.

11. On 19th May 2023 OFAC issued General License 13E authorising certain administrative transactions, General License 66 authorising the wind down of trasnactions involving PJSC Plyus, General License 67 authorising certain transactions related to debt or equity of, or derivative contracts involving, PJSC Polyus, and General License 68, authorising the wind down of transactions involving certain universities and institutes.

12. On 31st May 2023 OFAC issued General License 69 authorising certain debt securities servicing transactions involving the International Investment Bank.

Links 1

Executive Order 14024 - Blocking Property With Respect To Specified Harmful Foreign Activities Of The Government Of The Russian Federation (15/04/2021)
Determination Pursuant to Executive Order 14024 (Effective 22/02/2022) - Financial Services Sector of the Russian Federation Economy
Determination Pursuant to Section 1(a)(i) of Executive Order 14024 (Effective 31/03/2022) - Aerospace, Electronics, and Marine Sectors of the Russian Federation Economy
Determination Pursuant to Executive Order 14024 (Effective 08/05/2022) - Accounting, Trust and Corporate Formation Services, and Management Consulting Sectors of the Russian Federation Economy
Determination Pursuant to Executive Order 14024 (Effective 15/09/2022) - Quantum Computing Sector of the Russian Federation Economy
Determination Pursuant to Executive Order 14024 (Effective 24/02/ 2023) - Metals and Mining Sector of the Russian Federation Economy
Determination Pursuant to Executive Order 14024 (Effective 19/05/2023) - Architecture, Engineering, Construction, Manufacturing, and Transportation Sectors of the Russian Federation Economy
Determination Pursuant to Executive Order14024 (Effective 22/12/2023) - Certain Items Involving Russia's Military-Industrial Base
Executive Order 14065 - Blocking Property Of Certain Persons And Prohibiting Certain Transactions With Respect To Continued Russian Efforts To Undermine The Sovereignty And Territorial Integrity Of Ukraine (21/02/2022)
Executive Order 14114 - Taking Additional Steps With Respect to the Russian Federation’s Harmful Activities
Directive 1A - Prohibitions Related to Certain Sovereign Debt of the Russian Federation (22/02/2022)
Directive 3 - Prohibitions Related to New Debt and Equity of Certain Russia-related Entities (24/02/2022)
Directive 4 - Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation (19/05/2023)
General License 1A - Authorizing Certain Activities Involving Federal State Budgetary Institution Marine Rescue Service (20/08/2021)
General License 2 - Authorizing Certain Servicing Transactions Involving State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank (22/02/2022)
General License 7A - Authorizing Overflight Payments, Emergency Landings, and Air Ambulance Services (05/05/2022)
General License 13G - Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024 (02/11/2023)
General License 14 - Authorizing Certain Clearing and Settlement Transactions Prohibited by Directive 4 under Executive Order 14024 (02/03/2022)
General License 18 - Authorizing US Dollar-Denominated Banknote Noncommercial, Personal Remittances Prohibited by Executive Order of March 11, 2022 (11/03/2022)
General License 19 - Authorizing Transactions Related to Personal Maintenance of US Individuals Located in the Russian Federation Prohibited by Executive Order of March 11, 2022 (11/03/2022)
General License 20 - Authorizing Third-Country Diplomatic and Consular Funds Transfers (24/03/2022)
General License 27 - Certain Transactions in Support of Nongovernmental Organizations’ Activities (19/04/2022)
General License 40C - Civil Aviation Safety (14/11/2022)
General License 42 - Authorizing Certain Transactions with the Federal Security Service (28/06/2022)
General License 50 - Authorizing the Closing of Individual Accounts at Financial Institutions Blocked Pursuant to Executive Order 14024 (19/08/2022)
General License 52 - Journalistic Activities and Establishment of News Bureaus (15/09/2022)
General License 53 - Authorizing Transactions for Diplomatic Missions of the Russian Federation Prohibited by Directive 4 under Executive Order 14024 (10/11/2022)
General License 55A - Authorizing Certain Services Related to Sakhalin-2 (14/09/2023)
General License 62 - Authorizing the Wind Down of Transactions Involving Holdingovaya Kompaniya Metalloinvest AO, MegaFon PAO, Limited Liability Company USM Telecom, or Akkermann Cement Ca Limited Liability Company (12/04/2023)
General License 63 - Authorizing Transactions Related to Debt or Equity of, or Derivative Contracts Involving, Holdingovaya Kompaniya Metalloinvest AO (12/04/2023)
General License 64 - Authorizing Certain Transactions Involving Kommersant (12/04/2023)
General License 66 - Authorizing the Wind Down of Transactions Involving Public Joint Stock Company Polyus (19/05/2023)
General License 67 - Authorizing Certain Transactions Related to Debt or Equity of, or Derivative Contracts Involving, Public Joint Stock Company Polyus (19/05/2023)
General License 71 - Authorizing the Wind Down and Rejection of Transactions Involving Certain Entities Blocked on July 20, 2023 (20/07/2023)
General License 72 - Authorizing the Wind Down of Transactions Involving Certain Entities Blocked on September 14, 2023 (14/09/2023)
General License 75 - Authorizing Certain Transactions Related to Debt or Equity of, or Derivative Contracts Involving, Certain Entities Blocked on November 2, 2023 (02/11/2023)
General License 76A - Authorizing the Wind Down of Transactions Involving Certain Entities Blocked on November 2, 2023 (08/11/2023)
General License 85 - Authorizing the Wind Down of Transactions and the Closure of Accounts Involving Expobank JSC.
General License 88A, - Authorizing the Wind Down of Transactions Involving Certain Entities Blocked on 23rd February 2024
General License 89 - Authorizing the Wind Down and Rejection of Transactions Involving Certain Financial Institutions Blocked on 23rd February 2024
General License 90 - Authorizing Certain Transactions Related to Debt or Equity of, or Derivative Contracts Involving, Certain Entities Blocked on 23rd February 2024
General License 91A - Authorizing Limited Safety and Environmental Transactions Involving Certain Blocked Persons or Vessels
General License 92 - Authorizing the Offloading of Cargo from Sovcomflot Vessels
General License 93 - Authorizing Transactions Involving Certain Sovcomflot Vessels

On 15th December 2023 the UK introduced the Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2023 which bans the import of certain Russian metals; expands the payments processing restrictions to include non-sterling payments; prohibits the provision of technical assistance relating to luxury goods; provides statutory footing for annual frozen assets reporting to OFSI and imposed reporting obligations for designated persons; and included a licensing ground for divestment. Later that day the UK designated JSC Bank Novikombank, prohibiting correspondent banking relationships with the bank, imposing an asset freeze, and trusts services sanctions. A General Licence was issued allowing for the processing of payments for winding down with Novikombank.

On 23rd February 2024 OFSI sanctioned over 50 new individuals and entities sustaining Russia’s war in Ukraine, marking two years since the invasion. Sanctions targeted those supplying Russia’s depleted armoury with munitions such as rocket launch systems, missiles and explosives, as well as key sources of Russian revenue, clamping down on metals, diamonds, and energy trade.

Sanction Name

Russia (Sanctions) (EU Exit) Regulations 2019

SANCTIONS

Arms Embargo, Travel Ban, Trade Restrictions,

First Imposed

December 31, 2020

Last updated

March 27, 2024

Targets

Arms Embargo, Trade Restrictions and Travel Ban:
• Prohibition on the provision of long-term financial or investment services to state-owned Russian financial institutions, the export of arms and related materiel and on the supply of dual-use goods and technology to military end-users, as well as services, goods and technology related to deep water, Arctic and shale oil prospecting. The procurement from Russia of arms and related materiel is prohibited, and there is also a ban on trading in certain bonds, equities, and securities, as well as the provision of trust services, and other financial instruments.

•Designation of anyone either involved in destabilising Ukraine or undermining or threatening its territorial integrity, sovereignty or independence; or obtaining a benefit from or supporting the Government of Russia. Any trade relating to the so-called Donetsk People’s Republic (“DNR”) and Luhansk People’s Republic (“LNR”) are prohibited.

•Ban on Russian companies participating in UK capital markets and a ban on the Russian state raising sovereign debt in the UK.

• Prohibitions on the export of hi-tech and strategic industries. Russian nationals are only permitted to hold a maximum of £50,000 in one bank account. The UK also imposed sanctions on Minister of Foreign Affairs Sergey Lavrov and on President Putin on 25th February 2022.

•Prohibition of access to UK ports by Russian ships and other ships specified by the Secretary of State, as well as the provision of financial services to the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation.

•On 9th March 2022 OFSI further amended its Russian sanctions program, conferring on the Secretary of State the power to detain any aircraft overflying or landing in the UK that is “connected with Russia”.

•Ban on the export of high-end luxury goods to Russia.

• Prohibition of the provision of professional services to persons connected with Russia, including Russian residents temporarily located in another country, prohibiting the importation, acquisition, supply or delivery of Russian-origin gold, banning the export of energy-related goods to Russia, regardless of the eventual point of use, and also prohibiting the making available of energy-related goods to any persons connected with Russia.

• In response to the sham referenda and subsequent Russian annexation of Donetsk, Luhansk, Kherson and Zaporizhzhia, the UK introduced services export bans on IT consultancy, architectural services, engineering services, advertising services, auditing services, and transactional legal advisory services.

• Prohibition of the export, supply and delivery of goods for use in Russia that are deemed to be critical to the functioning of Russia’s economy. The prohibited goods are compiled in the Russia Vulnerable Goods list. The amendment also prohibits the import of certain other revenue generating goods, including but not limited to beverages, spirits, food waste products, and gold. A prohibition on the importation of Liquefied Natural Gas which is consigned from or originates in Russia came into force on 1st January 2023.

• Ban on the import of both Russian oil and oil products, in line with the other G7 governments. OFSI also banned the maritime transportation of Russian oil from 5th December 2022 and refined oil from 5th February 2023. The ban applies to the maritime transportation of the oil and oil products from a place in Russia to a third country, or from one third country to another third country. Similarly OFSI banned the associated services which facilitate this maritime transportation.

•Ban on the direct and indirect provision of auditing, advertising, architectural, engineering, and IT consultancy and design services to persons connected with Russia.

Exemptions

• In October 2022 OFSI issued two General Licenses under the Russia and Belarus sanctions regimes. The first indefinitely authorises designated people or entities to pay funds to the London Court of International Arbitration to cover arbitration costs, and the second authorises until 28th April 2023 the payment of legal fees by designated people and entities to law firms and counsel.

• On 2nd November 2022 OFSI published General Licence INT/2022/2339452, authorising Truphone Limited to provide telecommunication services, to pay remuneration, allowances and pensions, to pay fees and third-party providers necessary for the functioning of the business, and to make and receive payments due under contractual obligations. On 11th November 2022 OFSI amended the General Licence to add subsidiary companies of Truphone Limited and extend the licence expiry date until 28th April 2023.

• On 4th November 2022 OFSI issued General Licence INT/2022/2349952, which authorises certain transactions related to agricultural commodities, including the provision of insurance and other services.

• From 10th November 2022 until 10th November 2023 General Licence INT/2022/1919908 authorises non-designated persons to make use of the retail banking services of Credit or Financial Institutions designated under the UK’s Russia sanctions regime, provided that the payments are intended for the non-designated person’s personal use, and the total value of payments made by the non-designated person does not exceed £50,000

• On 5th December 2022 OFSI introduced a coordinated Oil Price Cap exception to the maritime transportation and associated services ban, making UK services available to third country importers and exporters, so long as the price paid for Russian oil or oil products is at or below the agreed price cap of $60 per barrel.

• On 16th February 2023 OFSI amended General Licence INT/2022/1839676 on Russian Travel to allow UK nationals or entities to purchase tickets from South Caucasus Railway CJSC for passenger rail journeys between Armenia and Georgia and within these countries. The General Licence will expire on 23rd May 2024.

• General License INT/2023/3024200 on Prior Obligations, permitting a UK person who is owed funds by a designated person under the Russia and Belarus sanctions programmes to receive payment, provided that the contractual obligation was signed before the person’s designation, the payment is for the benefit of a UK person, the value of the payments does not exceed £200,000, the designated person’s banks are permitted to transfer funds for this purpose, and no other UK person can use the General Licence to receive funds from the same contractual obligation. Certain contracts are not applicable under the General Licence, including professional legal fees, bonds, derivatives, and credit default swaps. The General License is effective from 22nd May 2023 and expires on 21st November 2023.

• General Licence INT/2023/3074680 permitting the trade in oil derivatives and futures previously prevented. The exemptions apply to individuals, organisations and brokers trading in derivatives and futures based on Russian oil, as well as institutions processing payments in relation to these activities.

• General Licence INT/2023/3263556 allowed payments and other actions to take place in relation to insolvency proceedings associated with GTLK, Russia’s largest state transport leasing company, the related Irish companies GTLK Europe DAC and GTLK Europe Capital DAC and their subsidiaries. GTLK Europe DAC and GTLK Europe Capital DAC were wound up by the Irish High Court on 31st May 2023.

• General License INT/2024/4398024 allowed payment of monies owed to designated persons into any Civil court pursuant to a Court Order.

• General License INT/2024/4576632

Links 1

Latest List of Targets
The Russia (Sanctions) (EU Exit) Regulations 2019
Russia Sanctions Amendments and Statutory Guidance
Guidance on Russian Oil Maritime Services Ban and Oil Price Cap
General Licence INT/2021/554388 - Emergency Payment(s) Directly or via an Intermediary to Belaeronavigatsia for Air Traffic Services
General Licence INT/2022/1280976 - Regulatory Authorities – Prudential Supervision, Financial Stability, Protection of Consumers Or Integrity of The UK Financial System
General Licence INT/2022/1280876 - Russian Banks: UK, Guernsey and EU Subsidiaries - basic needs, routine holding and maintenance and the payment of legal fees
General Licence INT/2022/1679676 - Law Enforcement and Regulatory Authorities Asset Recovery
General Licence INT/2022/1710676 - Evraz North American Subsidiaries
General Licence INT/2022/1678476 - Amsterdam Trade Bank N.V – winding down, basic needs and insolvency
General Licence INT/2022/1839676 - Russia Travel for UK Nationals
General Licence INT/2022/1834876 - Charities and Interim Managers and Trustees
General Licence INT/2022/1875276 - Continuation of Business and Basic Needs for Telecommunications Services and News Media Services
General Licence INT/2022/1947936 - Humanitarian Activity
General Licence INT/2022/2085212 - Mongolia Energy Payments
General Licence INT/2022/1845976 - Crown Servants, Contractors, and their Family Members
General Licence INT/2022/2104808 - Bank Fees
General Licence INT/2022/1552576 - LCIA Payments
General Licence INT/2022/2349952 - Transactions Related to Agricultural Commodities Including the Provision of Insurance and Other Services
General Licence INT/2022/2470156 - Oil Price Cap: Exempt Projects and Countries
General Licence INT/2022/2470056 - Correspondent Banking and Payment Processing
General Licence INT/2022/2470256 - Crude Oil Wind-down
General Licence INT/2023/2660772 - Product Oil Wind-down
General Licence INT/2022/2469656 - Oil Price Cap
General Licence INT/2023/2589788 - Wind-down of Trust Services Provided to Designated Persons
General Licence INT/2023/2824812 - Bond Amendments and Restructurings for Non-designated Persons
General Licence INT/2023/2883496 - Lithuania Rail
General Licence INT/2023/3024200 - Prior Obligations
General Licence INT/2023/3074680 - Oil Price Cap: Trading in Derivatives and Futures
General Licence INT/2023/3263556 - GTLK Companies and their Subsidiaries – Insolvency related payments and activities
General Licence INT/2023/3566356 - Correspondent Banking Payments
General Licence INT/2023/3744968 - Legal Services
General Licence INT/2023/4078352 - Payment Processing Wind Down
General Licence INT/2024/4423849 - Oil Price Cap
General License INT/2024/4576632- Transit to Port and Wind Down
General License- Court Funds Office Payments

Sanctions against Somalia originated in 1992, with a UN arms embargo seeking to limit the expansion of a civil war which began following the collapse of the government of Siad Barre. Current programmes are instituted in support of the UN-backed Federal Government of Somalia, which controls the capital, Mogadishu, and target Al Shabaab and other armed opposition groups.

On 1st December 2023 the UN lifted the general and complete arms ambargo on all deliveries of weapons and military equipment to Somalia. The UN subseuqently imposed an arms embargo on Al-Shabaab in Somalia, with exemptions and exceptions for other actors in Somalia. New measures do not apply to deliveries or supplies to the GFRS, SNA, NISA, SNPF and the Somali Custodial Corps; reaffirms the charcoal ban and IED components ban, and adjusts and adds to the list of components; renews the maritime interdiction of charcoal, weapons or military equipment, and IED components, until 15 December 2024; recalls that resolution 2664 (2022) supersedes and replaces the humanitarian exemption to the assets freeze in resolution 2662 (2022); renames the Committee; renews the mandate of the Panel of Experts, which the Council also renames, until 15 January 2025.

Sanction Name

Items Relating to the Situation in Somalia

First Imposed

April 24, 1992

Last updated

December 1, 2023

Targets

Asset Freeze, Arms Embargo, Travel Ban and Trade Restrictions:
• There is a ban on the sale of arms and military equipment to Al-Shabaab in Somalia. There are also asset freezes targeting those found to be undermining peace and stability in Somalia, violating the arms embargo, obstructing the delivery of humanitarian assistance, utilising child soldiers, committing acts of violence targeting women or children, engaging in international trade from Al Shabaab controlled ports or misappropriating Somalian financial resources. There is a ban on the trade of Somalian charcoal and on the export of various chemicals and components that can be used in the manufacture of improvised explosive devices (“IEDs”), including explosives containing nitrocellulose and trinitrophenylmethylnitramine as well as different kinds of detonators. 

Exemptions

1. Small arms supplied following notification to the UN Sanctions Committee for use by the Somalian Government or non-lethal equipment intended solely for humanitarian or protective use are exempt from sanctions. Weapons with a calibre of 12.7mm or greater require prior approval from the committee.

2. There are also travel ban exemptions for certain humanitarian purposes and to further the objectives of peace and stability in Somalia and the wider region.

3. Asset freeze exemptions can be granted for certain expenses.

4. An exemption applies to the arms embargo on Somalia for UN Member States engaged in the fight against piracy and armed robbery at sea.

Sanction Name

Restrictive in View Of The Situation In Somalia

SANCTIONS

Asset Freeze, Arms Embargo, Travel Ban, Trade Restrictions,

First Imposed

April 27, 2010

Last updated

March 19, 2024

Targets

Asset Freeze, Arms Embargo, Travel Ban and Trade Restrictions:
• Those engaged in or supporting violence undermining the Federal Government of Somalia or disrupting the provision of humanitarian assistance. The measure includes a ban on the provision of arms or related materiel or services to such individuals. Those breaching the arms embargo are also subject to special designation. There is also a prohibition on the importation of Somalian charcoal.

Exemptions

1. The arms and military training embargo does not apply to UN personnel, the African Union Mission in Somalia (AMISOM) or AMISOM’s strategic partners in the African Union, the European Union Training Mission, EU member states combatting piracy operations off the coast of Somalia, the Somali National Security Forces or the Somali security sector.

2. Small arms supplied following notification to the UN Sanctions Committee for use by the Somalian Government or non-lethal equipment intended solely for humanitarian or protective use is exempt from sanctions. Weapons with a calibre of 12.7mm or greater require prior approval from the committee.

3. There are also travel ban exemptions for certain humanitarian purposes and to further the objectives of peace and stability in Somalia and the wider region.

4. Asset freeze exemptions are also permitted for basic expenses, the provision of legal and professional services, fees for the holding of frozen funds and for the satisfaction of judicial, administrative or arbitral liens or judgments.

Sanction Name

Regulation on measures against Somalia

SANCTIONS

Asset Freeze, Arms Embargo, Travel Ban, Trade Restrictions,

First Imposed

May 13, 2009

Last updated

March 15, 2024

Targets

Asset Freeze, Arms Embargo, Travel Ban and Trade Restrictions:
• Entities engaged in military operations against the Transitional Federal Government (and its successor, the Federal Government of Somalia) and international peacekeeping forces during the country’s civil war. This includes an arms embargo, travel sanctions and the blocking of funds and economic resources, as well as restrictions on the importation of charcoal from Somalia and any related funding.

Exemptions

1. Arms supplied for use by the Somalian Government or non-lethal equipment intended solely for humanitarian or protective use is exempt from sanctions, as is the temporary export of protective clothing and related equipment for media, humanitarian, UN and Swiss personnel.

Sanction Name

Somalia Sanctions Program

SANCTIONS

Specially Designated National, Arms Embargo, Trade Restrictions,

First Imposed

April 13, 2010

Last updated

May 24, 2023

Targets

Specially Designated National, Arms Embargo and Trade Restrictions:
• Entities engaged in military operations against the Transitional Federal Government (and its successor, the Federal Government of Somalia) and international peacekeeping forces during the country’s civil war, including those found to have supplied or supported the supply into the country of arms or materiel. The sanctions also target any entity found to be responsible for acts of violence targeting civilians, political or military leaders using children in armed conflict. The importation of charcoal from Somalia into the US is prohibited and sanctions also target any individuals found to be trading in Somalian charcoal after 22nd February 2012.

Sanction Name

Restrictive in View Of The Situation In Somalia

SANCTIONS

Asset Freeze, Arms Embargo, Travel Ban, Trade Restrictions,

First Imposed

December 31, 2020

Last updated

May 31, 2023

Targets

Asset Freeze, Arms Embargo, Travel Ban and Trade Restrictions:
• Those engaged in or supporting violence undermining the Federal Government of Somalia or disrupting the provision of humanitarian assistance. The measure includes a ban on the provision of arms or related materiel or services to such individuals. Those breaching the arms embargo are also subject to special designation. There is also a prohibition on the importation of Somalian charcoal.

Exemptions

1. The arms and military training embargo does not apply to UN personnel, the African Union Mission in Somalia (AMISOM) or AMISOM’s strategic partners in the African Union, the European Union Training Mission, EU member states combatting piracy operations off the coast of Somalia, the Somali National Security Forces or the Somali security sector.

2. Small arms supplied following notification to the UN Sanctions Committee for use by the Somalian Government or non-lethal equipment intended solely for humanitarian or protective use are exempt from sanctions. Weapons with a calibre of 12.7mm or greater require prior approval from the committee.

3. There are also travel ban exemptions for certain humanitarian purposes and to further the objectives of peace and stability in Somalia and the wider region.

4. Asset freeze exemptions are also permitted for basic expenses, the provision of legal and professional services, fees for the holding of frozen funds and for the satisfaction of judicial, administrative or arbitral liens or judgments.

UN-led sanctions on South Sudan were initially imposed to prevent the escalation of the civil war in that country from 2013 to 2018. They remain in place, targeting those deemed to have committed serious human rights abuses during the conflict.

On 30th May 2023 the UN extended the arms embargo in place against South Sudan for a further year until 31st May 2024.

Sanction Name

UN Security Council Regulations Against South Sudan

First Imposed

March 3, 2015

Last updated

May 30, 2023

Targets

Arms Embargo, Travel Ban and Asset Freeze:
• Entities seeking to overthrow the government of South Sudan, as well as any individuals found to be involved in the commission of human rights abuses, obstructing international peacekeeping forces or humanitarian bodies, targeting civilians, using child soldiers or providing arms or material support to such entities.

Exemptions

1. Travel ban exemptions are in place for travel on humanitarian grounds, to support the fulfilment of judicial processes or to advance peace and stability in South Sudan.

2. There is also an exemption on frozen assets with regard to judicial, administrative or arbitral liens or judgments, as well as on interests, earnings and payments due under contracts, agreements or obligations entered into prior to the listing of a sanctioned party.

3. Arms Embargo exemptions are in place for arms and related materiel temporarily exported to South Sudan for the personal use of UN, media and development personnel, as well as the forces of states taking action in the country legally. There is also an exemption in place for arms and related materiel intended solely to provide training and support to the African Union Regional Task Force, or to support the implementation of the peace agreement.

Sanction Name

Restrictive Measures In Respect Of The Situation In South Sudan

SANCTIONS

Asset Freeze, Arms Embargo, Travel Ban,

First Imposed

May 8, 2015

Last updated

April 4, 2023

Targets

Arms Embargo, Travel Ban and Asset Freeze:
• Entities seeking to overthrow the government of South Sudan, as well as any individuals found to be involved in the commission of human rights abuses, obstructing international peacekeeping forces or humanitarian bodies, targeting civilians, using child soldiers or providing arms or material support to such entities.

Sanction Name

Order Establishing Measures Against The Republic Of South Sudan

SANCTIONS

Asset Freeze, Arms Embargo, Travel Ban,

First Imposed

August 12, 2015

Last updated

March 15, 2024

Targets

Arms Embargo, Travel Ban and Asset Freeze:
• Entities seeking to overthrow the government of South Sudan in the wake of the country’s civil war, as well as any individuals found to be involved in the commission of human rights abuses, obstructing international peacekeeping forces or humanitarian bodies, targeting civilians, using child soldiers or providing arms or material support to such entities. The criteria include parties providing financial services, technical advice and the provision of armed mercenaries to sanctioned parties.

Exemptions

1. Exemptions for sanctioned individuals travelling through Switzerland for humanitarian purposes, for participation in international conferences concerning political discussions on South Sudan or if the protection of Swiss interests requires it.

2. Asset freeze exemptions can be granted to prevent cases of rigor; in respect of existing contracts; to respect credits due under existing judicial, administrative or arbitral judgments; or to protect Swiss interests.

3. Non-lethal equipment intended solely for the UN, the EU, the African Union and Switzerland as well as for humanitarian or protective use is exempt from sanctions, as is demining equipment and non-combat vehicles equipped with ballistic defence materials.

Marking the 75th anniversary of the Universal Declaration of Human Rights, on 8th December 2023 OFAC designated Gordon Koang Biel, Gatluak Nyang Hoth, and Joseph Mantiel Wajang, the Koch County Commissioner, the Mayendit County Commissioner, and the Unity State Governor, respectively. Between February and April 2022, government-aligned forces and allied militias under Biel and Hoth’s command were responsible for systematic rape, often accompanied by other human rights violations, perpetrated against women and girls during armed attacks in Leer County of Unity State.

Sanction Name

South Sudan Sanctions Program

SANCTIONS

Specially Designated National, Arms Embargo, Travel Ban,

First Imposed

April 3, 2014

Last updated

December 8, 2023

Targets

Arms Embargo, Travel Ban and Asset Freeze:
• Entities seeking to overthrow the government of South Sudan, as well as any individuals found to be involved in the commission of human rights abuses, obstructing international peacekeeping forces or humanitarian bodies, targeting civilians, using child soldiers or providing arms or material support to such entities.

Sanction Name

South Sudan (Sanctions) (EU Exit) Regulations 2020

SANCTIONS

Asset Freeze, Arms Embargo, Travel Ban,

First Imposed

December 31, 2020

Last updated

March 8, 2023

Targets

Arms Embargo, Travel Ban and Asset Freeze:
• Entities seeking to overthrow the government of South Sudan, as well as any individuals found to be involved in the commission of human rights abuses, obstructing international peacekeeping forces or humanitarian bodies, targeting civilians, using child soldiers or providing arms or material support to such entities.

The US designated Sudan as an international terrorist sponsor in 1993, imposing various trade restrictions. Although relations improved during the early 2000s, the US, alongside the UN and the EU, imposed wide ranging trade restrictions and sanctions targeting the Sudanese government in 2005, in response to violence and human rights abuses committed as part of the civil war. UN, UK, SECO and EU sanctions remain in place targeting parties presenting a threat to the settlement of the civil war, although US programmes targeting the Sudanese government have been discontinued.

On 8th March 2023 the Sudan sanctions programme was extended until 12th September 2024.

Sanction Name

UN Security Council Regulations Against Sudan

First Imposed

March 29, 2005

Last updated

March 8, 2024

Targets

Arms Embargo, Travel Ban and Asset Freeze:
• Entities deemed to present a threat to stability and security in Darfur and the wider region or those committing human rights abuses. An embargo on the supply of arms to entities operating in Darfur and all signatories of the N’djamena Ceasefire Agreement.

Exemptions

1. The Sudanese Government can move military equipment and supplies into the Darfur region following approval from the UN Sanctions Committee.

2. There is also an exemption on frozen assets with regards to judicial, administrative or arbitral liens or judgments.

3. Travel ban exemptions can be granted on a case-by-case basis on humanitarian grounds.

On 22nd January 2024 the European Council designated six entities for supporting activities undermining the stability and political transition of Sudan including two companies involved in the manufacture of weapons and vehicles for the Sudanese Armed Forces (“SAF”) (Defense Industries System and SMT Engineering), SAF-controlled Zadna International COmpany for Investment Limited, and three companies involved in procuring military equipment for the Rapid Support Forces (Al Junaid Multi Activities Co Ltd, Tradive General Trading andGSK Advance Company Ltd).

Sanction Name

Restrictive Measures In View Of The Situation In Sudan

SANCTIONS

Asset Freeze, Arms Embargo, Travel Ban,

First Imposed

May 30, 2005

Last updated

January 22, 2024

Targets

Arms Embargo, Travel Ban and Asset Freeze:
• Individuals or groups threatening the peace process following the country’s civil war and the secession of South Sudan, threatening the stability of Darfur or participating in human rights abuses. The programme includes a ban on all exports of materiel or related equipment or services into Sudan.

Exemptions

1. Exemptions can be granted on a case-by-case basis where they would further peace and stability in Sudan and the wider region.

2. Asset freeze exemptions are also permitted for basic expenses, the provision of legal and professional services, fees for the holding of frozen funds and for the satisfaction of judicial, administrative or arbitral liens or judgments.

Sanction Name

Regulation on Measures Against Sudan

SANCTIONS

Asset Freeze, Arms Embargo, Travel Ban, Trade Restrictions,

First Imposed

May 25, 2005

Last updated

June 1, 2023

Targets

Arms Embargo, Travel Ban, Trade Restrictions and Asset Freeze:
• Sanctions were introduced in response to the genocide in Darfur and targeting those found to be impeding the peace process, constituting a threat to stability in Darfur and the region, committing violations of international humanitarian or human rights law or other atrocities, or responsible for offensive military overflights.

Exemptions

1. Arms supplied for use by the UN or non-lethal equipment intended solely for humanitarian or protective use is exempt from sanctions, as is the temporary export of protective clothing and related equipment for media, humanitarian, UN and Swiss personnel.

2. Asset freeze exemptions can be granted to prevent cases of rigor or to protect Swiss interests. Travel ban exemptions can be granted to protect Swiss interests.

On 31st January 2024 OFAC sanctioned three entities for their role in undermining the peace, security, and stability of Sudan as part of the US’ attempt to identify and isolate funding sources for both the Sudanese Armed Forces (“SAF”) and the Rapid Support Forces (“RSF”), the two main belligerent parties responsible for the conflict in Sudan. Designations included RSF-controlled Alkhaleej Bank Co Ltd, which finances RSF’s operations; RSF-controlled Al-Fakher Advanced Works Co Ltd, a holding company for conducting RSF’s gold export business; and SAF-controlled, Zadna International Co for Development Ltd, allegedly a vehicle for military money-laundering and revenue generation for the SAF.

On 1st March 2024, OFAC amended the heading of the Darfur Sanctions Regime to the Sudan Stabliziation Sanctions Regulations.

Sanction Name

US Sanctions against Sudan

SANCTIONS

Specially Designated National, Trade Restrictions, Arms Embargo,

First Imposed

November 4, 1997

Last updated

March 1, 2024

Targets

Arms Embargo, Travel Ban and Asset Freeze:
• Entities deemed to present a threat to stability and security in Darfur and the wider region or those committing human rights abuses.
• Export controls remain in place, including on arms and dual-use goods. A licence is required to export certain commodities, software, and technology on the Commerce Control List.

Exemptions

1. Effective from October 2017 US persons are no longer prohibited from financial transactions in Sudan, including with the Government of Sudan, as detailed in the Sudanese Sanctions Regulations.
2. An OFAC General License permits the export agricultural commodities, medicine or medical devices to the Government of Sudan.
3. Exemptions can be granted for certain transactions relating to humanitarian exceptions.
4. Exemptions apply to the wind down of transactions involving paramilitary group Rapid Support Forces-associated entities Defence Industries System or Al Junaid Multi Activities Co Ltd.

Sanction Name

Sudan (Sanctions) (EU Exit) Regulations 2020

SANCTIONS

Asset Freeze, Arms Embargo, Travel Ban,

First Imposed

December 31, 2020

Last updated

July 20, 2023

Targets

Arms Embargo, Travel Ban and Asset Freeze:
• Individuals or groups threatening the peace process following the country’s civil war and the secession of South Sudan, threatening the stability of Darfur or participating in human rights abuses. The programme includes a ban on all exports of materiel or related equipment or services into Sudan.

Exemptions

1. Exemptions can be granted on a case-by-case basis where they would further peace and stability in Sudan and the wider region.

2. Asset freeze exemptions are also permitted for basic expenses, the provision of legal and professional services, fees for the holding of frozen funds and for the satisfaction of judicial, administrative or arbitral liens or judgments.

The US has operated a sanctions programme targeting the Syrian government since 2004, focused on its association with the financing of terrorism and its historical occupation of Lebanon. Sanctions against the Syrian government and a wide ranging trade embargo were imposed by the EU and SECO in 2012, in response to human rights abuses committed by the government of Bashar Al Assad during the country’s civil war.

On 22nd January 2024 the EU designated six individuals and five entities in view of the situation in Syria, including three leading businesspersons operating in various sectors including logistics, tourism, trading, and pharmaceuticals, reportedly supporting and benefiting from the regime; two individuals connected to the Assad family; and three entities allegedly connected to the transfer of Syrian mercenaries, arms trade, narcotics trafficking, and money laundering.

Sanction Name

Restrictive Measures In View Of The Situation In Syria

First Imposed

January 8, 2012

Last updated

January 22, 2024

Targets

Asset Freeze, Arms Embargo, Trade Restrictions and Travel Ban:
• Syrian President Bashar Al Assad and officials in his government implicated in human rights abuses committed during the country’s civil war. The programme includes wide ranging restrictions on trade with Syria, including an embargo on the export to the country of arms, telecommunications monitoring and interception equipment, jet fuel, equipment for the oil and natural gas sector, gold, precious metals, diamonds, banknotes or coins or luxury goods. There are also prohibitions on investment in the oil and gas sector or in electricity production, trading in Syrian financial instruments, co-operation with Syrian banks, providing insurance or reinsurance services or trading in Syrian cultural goods. The importation of Syrian crude oil and petroleum products or the provision of financial services to the government of Syria is banned, with the sole exception of its use for humanitarian purposes. There are also restrictions on access to airports in the EU for certain flights.

Exemptions

1. The purchase of oil and petroleum products and the related provision of financing or financial assistance in Syria for the sole purpose of providing humanitarian relief or assistance to the Syrian civil population is authorised.

2. Exemptions can also be granted on a case-by-case basis on humanitarian grounds or to support the attendance of inter-governmental meetings.

3. Exemptions can be granted on activities and transactions necessary to facilitate humanitarian assistance in relation to earthquake relief efforts in Syria and Turkey.

Sanction Name

Restrictive Measures Related To Assassination Of Prime Minister Rafiq Hariri

SANCTIONS

Asset Freeze,

First Imposed

December 14, 2005

Last updated

February 16, 2023

Targets

Asset Freeze:
• Individuals – including both Lebanese and Syrian nationals – suspected of involvement in the assassination of Prime Minister Rafiq Hariri.

Exemptions

1. Exemptions can be granted on a case-by-case basis on humanitarian grounds or to support the attendance of inter-governmental meetings, as well as for basic expenses, the provision of legal and professional services and fees for the holding of frozen funds.

On 21st February 2024 the Swiss Federal Council extended for a further six months the temporary humanitarian exemption introduced after the February 2023 earthquake in Syria. The exemption now applies until 12th September 2024

Sanction Name

Order establishing measures against Syria

SANCTIONS

Asset Freeze, Arms Embargo, Trade Restrictions,

First Imposed

May 18, 2011

Last updated

March 15, 2024

Targets

Asset Freeze, Arms Embargo and Trade Restrictions:
• Officials and associates of the Syrian government or any Syrian national deemed to be responsible for the violent repression of the civilian population. The programme includes a ban on the export to Syria of arms or related materiel, or the provision of related financial or technical services, the importation of Syrian petroleum products or the financing of such trade, support for the mining or refining of Syrian crude oil or the supply of equipment or technology for such purposes, the provision of aviation fuel, support for the construction of new power plants, the provision of equipment or technology for monitoring services, the provision of banknotes, coins, diamonds or precious metals, trading in cultural goods or the provision of insurance, reinsurance or other financial services.

• SECO prohibits all Swiss airports from accepting flights operated by Syrian Arab Airlines and all freight flights operated by Syrian transport companies, with the exception of mixed-passenger freight flights and humanitarian flights.

Exemptions

1. With the authorisation of SECO, restrictions can be lifted for goods, services, oil and petroleum products intended solely for humanitarian purposes, as well as for use by non-Syrian civil aircraft or by Syrian airlines for evacuations.

2. Arms supplied for use by the UN and non-lethal equipment intended solely for humanitarian or protective use are exempt from sanctions, as are hunting and sporting weapons.

3. Asset freeze exemptions can be granted to prevent cases of rigor; in respect of existing contracts; to respect credits due under existing judicial, administrative or arbitral judgments; to provide humanitarian aid; to protect Swiss interests; to financially support Syrian citizens at university or receiving professional training in Switzerland; to destroy chemical weapons and related facilities; or for Syrian diplomatic missions and consular posts.

4. Travel ban exemptions may be granted on humanitarian grounds, to attend international conferences, to participate in political dialogue concerning Syria or if the protection of Swiss interests requires it.

5. Exemptions from certain financial transactions may be granted if these are necessary for the provision of humanitarian aid or for the support of the civilian Syrian population by public authorities and other organisations. Financial transactions necessary for diplomatic and consular missions in Syria are also exempt.

6. Exemptions were granted for the six months following the earthquake on 6th February 2023 to facilitate humanitarian assistance.

On 26th March 2024, OFAC sanctioned six entities, one individual and two tankers that are based or registered in Liberia, India, Vietnam, Lebanon, and Kuwait that have engaged in facilitating commodity shipments and financial transactions for the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF), the Houthis, and Hizballah. This action, the sixth round of sanctions targeting the network of Iran-based, IRGC-QF-backed Houthi financial facilitator Sa’id al-Jamal since December 2023, represents yet another step in a concerted campaign to disrupt IRGC-QF finances and its support to terrorist proxies such as the Houthis.

On the same date, OFAC sanctioned 11 individuals and entities supporting the regime of Syrian President Bashar Al-Assad through the facilitation of illicit financial transfers and trafficking of illegal drugs, as well as the extraction and export of Syrian commodities.

Sanction Name

Syria Sanctions Program

SANCTIONS

Specially Designated National, Trade Restrictions,

First Imposed

May 11, 2004

Last updated

March 26, 2024

Targets

Specially Designated National and Trade Restrictions:
• The Government of Syria and entities under its control. The programme also includes a complete prohibition on new investment in the country by US entities, a ban on the direct or indirect export of goods or services to Syria and on the importation into the US of petroleum or petroleum products of Syrian origin. There is also a ban on the financing or facilitation of such activities by third parties.

Exemptions

1. Certain transactions that support the publishing and marketing of manuscripts, books, journals and newspapers in paper and electronic format are authorised.

2. Certain activities in response to the Covid-19 pandemic.

3. Activities in certain economic sectors in non-regime held areas of Northeast and Northwest Syria.

4. Until 8th August 2023 all transactions related to earthquake relief that would otherwise be prohibited under the Syrian Sanctions Regulations

Links 1

Syria Sanctions Overview
Syrian Sanctions Regulations
Iran Threat Reduction and Syria Human Rights Act of 2012 H.R. 1905 (PL 112-158)​
Caesar Syria Civilian Protection Act of 2019 (Sections 7404-7438 of the National Defense Authorization Act for Fiscal Year 2020)​
Executive Order 13338 - Blocking Property of Certain Persons and Prohibiting the Export of Certain Goods to Syria (12/05/2004)
Executive Order 13399 - Blocking Property of Additional Persons in Connection With the National Emergency With Respect to Syria (26/04/2006)
Executive Order 13460 - Blocking Property of Additional Persons in Connection With the National Emergency With Respect to Syria (15/02/2008)
Executive Order 13572 - Blocking Property of Certain Persons with Respect to Human Rights Abuses in Syria (29/04/2011)​
Executive Order 13573 - Blocking Property Of Senior Officials Of The Government Of Syria (18/05/2011)​
Executive Order13582 - Blocking Property of the Government of Syria and Prohibiting Certain Transactions with Respect to Syria (18/08/2011)​
Executive Order 13606 - Blocking the Property and Suspending Entry Into the United States of Certain Persons With Respect to Grave Human Rights Abuses by the Governments of Iran and Syria via Information Technology​ (23/04/2012)
Executive Order 13608 - Prohibiting Certain Transactions With and Suspending Entry Into the United States of Foreign Sanctions Evaders With Respect to Iran and Syria​ (01/05/2012)
General License 21B - Authorizing Certain Activities to Respond to the Coronavirus Disease 2019 (14/06/2023)
General License 22 - Authorizing Activities in Certain Economic Sectors in Non-Regime Held Areas of Northeast and Northwest Syria (12/05/2022)
Guidance for the Provision of Humanitarian Assistance to Syria (08/08/2023)
Guidance to Address Illicit Shipping and Sanctions Evasion Practices​​​ (14/05/2020)
Guidance on Sanctions Risks Related to Shipping Petroleum to Syria (25/03/2019)​

Sanction Name

Restrictions on the Turkish government in view of the Situation in Syria

SANCTIONS

Specially Designated National,

First Imposed

October 14, 2019

Last updated

August 17, 2023

Targets

Specially Designated National:
• Persons deemed to be responsible for or engaged or complicit in policies that threaten peace and stability in Syria or those ordering human rights abuses. Current or former officials of the Government of Turkey, including those who are deemed to work on or behalf of persons who are targeted by sanctions. Persons working in specific sectors in Turkey as determined by the Secretary of the Treasury. • Persons engaged in or financing the obstruction or prevention of a ceasefire in northern Syria. Persons involved in the intimidation of persons returning to their place of residence or forced repatriation of refugees to Syria. The sanction also targets those engaged in blocking UN-led political solutions to the crisis. Family members of these targets may also be sanctioned and anyone engaged in expropriation of property in Syria.

Exemptions

1. All actions committed by US government employees or contractors conducting official US Government business.

On 8th February 2024 OFSI extended the Syrian General Licence related to humanitarian exemptions for a further six months until 14th August 2024.

Sanction Name

Restrictive Measures In View Of The Situation In Syria

SANCTIONS

Asset Freeze, Arms Embargo, Travel Ban, Trade Restrictions,

First Imposed

December 31, 2020

Last updated

February 8, 2024

Targets

Asset Freeze, Arms Embargo, Trade Restrictions and Travel Ban:
• Syrian President Bashar Al Assad and officials in his government implicated in human rights abuses committed during the country’s ongoing civil war. The programme includes wide ranging restrictions on trade with Syria, including an embargo on the export to Syria of arms, telecommunications monitoring and interception equipment, jet fuel, equipment for the oil and natural gas sector, gold, precious metals, diamonds, banknotes or coins, luxury goods, investment in the oil and gas sector or in electricity production, trading in Syrian financial instruments, co-operation with Syrian banks, providing insurance or reinsurance services or trading in Syrian cultural goods. There is also a ban on the importation of Syrian crude oil and petroleum products or the provision of financial services to the government of Syria, with the sole exception of its use for humanitarian purposes. There are also restrictions on access to airports in the EU for certain flights.

Exemptions

1. The purchase of oil and petroleum products and the related provision of financing or financial assistance in Syria for the sole purpose of providing humanitarian relief or assistance to the Syrian civil population is authorised.

2. Exemptions can also be granted on a case-by-case basis on humanitarian grounds or for the attendance of inter-governmental meetings.

3. Activities and transactions necessary to facilitate humanitarian assistance in relation to earthquake relief efforts in Syria and Turkey.

The EU initiated sanctions against Tunisia in 2011, targeting those involved in widespread state corruption under deposed President Zine El Abedine Ben Ali, who fled the country that year following a popular uprising.

On 29th January 2024 the EU extended its Tunisia sanctions programme until 31st January 2025.

Sanction Name

Restrictive In View Of The Situation In Tunisia

First Imposed

February 2, 2011

Last updated

January 31, 2024

Targets

Asset Freeze:
• Individuals involved in state corruption or the theft of government assets during the government of President Zine El Abedine Ben Ali.

On 14th October 2019 then US President Donald Trump announced that the US would implement sanctions against Turkey in response to the latter’s military offensive in Northern Syria and its potential to destabilise the region. Specifically, the Office of Foreign Assets Control claimed that the military action could undermine efforts to defeat ISIS/Daesh, endanger civilians and further threaten the security and stability of the region. No entities are currently sanctioned under this legislation, although it remains in force, allowing the US government to act quickly against any breaches of the current ceasefire agreement.

The EU sanctions programme is due to expire on 29th November 2024.

Sanction Name

Restrictive measures in view of Turkey’s unauthorised drilling activities in the Eastern Mediterranean

SANCTIONS

Asset Freeze, Travel Ban,

First Imposed

November 11, 2019

Last updated

November 11, 2023

Targets

Asset Freeze and Travel Ban:
• Restrictive measures, including asset freezes and travel bans, against natural persons or entities responsible for, involved in or assisting drilling activities, which have not been authorised by the Republic of Cyprus, within its territorial sea or in its exclusive economic zone or on its continental shelf.

On 10th February 2023 OFAC issued General Licence 23, which authorises until 8th August 2023 all transactions related to earthquake relief that would otherwise be prohibited under the Syrian Sanctions Regulations. On 21st February 2023 OFAC issued guidance on authorised transactions related to earthquake relief efforts in Syria in response to questions from the NGO community on how to provide assistance to Syria while complying with OFAC sanctions.

Sanction Name

Restrictions on the Turkish government in view of the Situation in Syria

First Imposed

October 14, 2019

Last updated

February 21, 2023

Targets

Specially Designated National:
• Persons deemed to be engaged, responsible or complicit in policies that threaten peace and stability in Syria or those ordering human rights abuses. Current or former officials of the Government of Turkey, including those who are deemed to work on or behalf of persons who are targeted by sanctions. Persons working in specific sectors in Turkey as determined by the Secretary of the Treasury. • Persons engaged in or financing the obstruction or prevention of a ceasefire in northern Syria. Persons involved in the intimidation of persons returning to their place of residence or forced repatriation of refugees to Syria. The programme also targets those engaged in blocking UN-led political solutions to the crisis. Family members of these targets may also be sanctioned and anyone engaged in expropriation of property in Syria.
•On 23rd October 2019 five individuals and entities were removed from the OFAC SDN list after Turkey agreed to a ceasefire. No individuals or entities are currently sanctioned by the programme.

Exemptions

1. All actions committed by US government employees or contractors conducting official US Government business.

Ukrainian sanctions programmes, first instituted in 2014 in response to the Russian annexation of Crimea and civil conflict in the country’s Eastern provinces, target businesses operating in Russian controlled areas, assets misappropriated during the unrest, militant groups opposing Ukrainian control of its territory and Russian officials active in support of them or deemed to be responsible for Russian aggression.

On 23rd June 2023 the EU extended its trade embargo concerning restrictions on goods originating in Crimea and Sevastopol for a further twelve months.

Sanction Name

Restrictive Measures In Response To The Illegal Annexation Of Crimea And Sevastopol

First Imposed

June 23, 2014

Last updated

October 6, 2022

Targets

Trade Restrictions:
• Ban on the importation of goods from or investment in assets in Crimea or Sevastopol. Prohibition of the export to Crimea and Sevastopol of goods and technology for use in the sectors of transport, telecommunications, energy, oil, gas, infrastructure and mineral resources or related services, as well as services related to tourism. Prohibition of certain ships from entering ports in Crimea and Sevastopol.

Sanction Name

Restrictive measures in response to the recognition of the non-government controlled areas of the Donetsk and Luhansk oblasts of Ukraine and the ordering of Russian armed forces into those areas

SANCTIONS

Trade Restrictions,

First Imposed

February 23, 2022

Last updated

February 22, 2023

Targets

Trade Restrictions:
•Prohibit the importation of goods from or investment in assets in the so-called Donetsk People’s Republic (“DNR”) or the Luhansk People’s Republic (“LNR”). Prohibition of the export to the DNR and LNR of goods and technology for use in the sectors of transport, telecommunications, energy, oil, gas, infrastructure and mineral resources or related services, as well as services related to tourism.

•On 10th March 2022 the EU prohibited the sale, supply, transfer or export of maritime navigation goods and technology to any person/entity in Russia, for use in Russia, or for the placing on board of a Russian-flagged vessel.

•On 8th April 2022 the EU announced a new raft of trade restrictions in response to the ongoing conflict in Ukraine, which prohibit the importation into the EU of Russian origin coal, wood, cement, fertilisers, seafood and liquor. Access to EU ports is prohibited for Russia-flagged vessels, alongside a range of specific export bans on sensitive products such as jet fuel, quantum computers and high-end electronics.

Exemptions

1. On 21st July 2022 the EU announced a sanctions package containing a series of amendments designed to close existing loopholes and extend the current measures against Russia. These amendments included extending the list of controlled items to include anything which might contribute to Russia’s military or technological enhancement.

Sanction Name

Restrictive Measures In View The Situation In Ukraine

SANCTIONS

Arms Embargo, Travel Ban, Trade Restrictions,

First Imposed

July 31, 2014

Last updated

February 24, 2024

Targets

Arms Embargo, Trade Restrictions and Travel Ban:
• Prohibition on the provision of long-term financial or investment services to state-owned Russian financial institutions, the export of arms and related materiel and on the supply of dual-use goods and technology to military end-users, as well as services, goods and technology related to deep water, Arctic and shale oil prospecting. The procurement from Russia of arms and related materiel is prohibited, and there is also a ban on trading in certain bonds, equities and other financial instruments.

• All Russian Central Bank assets have been frozen and there is a ban on providing any loans or investments or investment services to the Government of Russia and the Central Bank.

•On 28th February 2022 the EU implemented financial restrictions via Council Decision 2022/327 and Council Regulation 2022/328 which banned transactions with the Central Bank of Russia and prohibited the acceptance of any deposits from Russian nationals exceeding a total value of €100,000. On 2nd March 2022 the EU prohibited the provision of SWIFT services to Bank Otkritie, Novikombank, Promsvyazbank, Bank Rossiya, Sovcombank, VNESHECONOMBANK and VTB Bank. Investment, participation or financing of the Russian Direct Investment Fund was also prohibited.

•On 3rd June 2022 the European Commission adopted the ‘sixth package’ of sanctions against Russia and Belarus, including an import ban on Russian crude oil and petroleum products, export measures on 92 entities, and a suspension of the broadcasting of Russian state channels in the EU. The Commission also extended the existing prohibition from SWIFT to Sberbank, Credit Bank of Moscow, the Russian Agricultural Bank, and the Belarusian Bank for Development and Reconstruction.

Exemptions

1. On 30th November 2017 the EU permitted certain operations concerning hydrazine in concentrations of 70% or more, necessary for the ExoMars 2020 joint mission between the European Space Agency and the Roscosmos State Corporation.

Sanction Name

Restrictive Measures In Respect Of Actions Undermining Or Threatening Ukraine

SANCTIONS

Asset Freeze, Travel Ban,

First Imposed

March 17, 2014

Last updated

March 12, 2024

Targets

Asset Freeze and Travel Ban:
• Ukrainian Sovereignty and Security – Those deemed to be responsible for or supporting actions which threaten the security, territorial integrity, sovereignty and independence of Ukraine, or obstruct the work of international organisations there. Also explicitly targets Russian policymakers responsible for the annexation of Crimea and the destabilisation of Eastern Ukraine, or any entities conducting transactions with separatist groups in Ukraine’s Donbass region. The sanctions programme also targets entities in Crimea and Sevastopol which have had their ownership transferred contrary to Ukrainian law and the beneficiaries of such transfers.

• A number of military, political and business figures have been personally sanctioned.

Exemptions

1. Exemptions can be granted on a case-by-case basis on humanitarian grounds or for the attendance of inter-governmental meetings.

Sanction Name

Restrictive Measures In View Of The Situation In Ukraine

SANCTIONS

Asset Freeze,

First Imposed

March 5, 2014

Last updated

March 4, 2023

Targets

Asset Freeze:
• Funds and economic resources controlled by those who have misappropriated Ukrainian state assets or those responsible for human rights violations in the country have been frozen.

Sanction Name

Measures To Prevent The Circumvention Of International Sanctions In Relation To The Situation In Ukraine

SANCTIONS

Asset Freeze, Arms Embargo, Trade Restrictions,

First Imposed

March 6, 2015

Last updated

March 22, 2024

Targets

Asset Freeze:
• Any entities found to be responsible for or complicit in undermining democratic processes or institutions in Ukraine during the country’s ongoing civil conflict, including the assertion of governmental authority over any area of the country without the authorisation of the Government of Ukraine. The assets of the Central Bank of Russia are frozen.

Trade Restrictions:
• Strict controls on investment in Russia and Ukraine, including a prohibition on the provision of loans to companies in Crimea and Sevastopol and on investment in companies and real estate there. The same applies to the so-called Donetsk People’s Republic (“DNR”) and the Luhansk People’s Republic (“LNR”).
• The provision of tourism-related services in the Crimea region is banned and documentation from the Ukrainian authorities is required for the export of goods originating there. Financing relating to the export of goods from Sevastopol and Crimea is prohibited. The same applies to the DNR and LNR.
• There are controls on the issuance of short-term financial instruments to banks and companies in Russia and Ukraine. Financing and finance services to the Russian government and Central Bank of Russia are prohibited.
• Reporting obligations are in place for financial intermediaries and companies providing certain services and technical assistance to listed companies or exporting goods used in prospecting for crude oil in Arctic, deepwater or shale projects.
•On 13th April 2022 SECO announced that it had formally mirrored the latest sanctions package implemented by the EU, the focus of which was a set of new trade restrictions against a number of strategic sectors of the Russian economy, including coal, luxury goods, wood, and cement.

Arms Embargo:
• A ban on the export of dual use and military goods to Russia.
• The importation of military equipment from Russia or Ukraine is banned.

Exemptions

1. There are exemptions for business entered into before the imposition of sanctions in March 2015. Financial instruments with Russian banks which have a maturity exceeding 30 days that were arranged prior to 12th November 2014 are also exempt. 2.SECO may grant exemptions from trade restrictions if goods exported to Crimea and Sevastopol are necessary to prevent serious health or safety hazards, including goods used for the protection of existing infrastructure and the environment.

Sanction Name

Restrictions Involving the Russian-Occupied Regions of Ukraine

SANCTIONS

Specially Designated National, Travel Ban, Trade Restrictions,

First Imposed

March 6, 2014

Last updated

July 20, 2023

Targets

Specially Designated National and Travel Ban:
• Any entities found to be responsible for or complicit in undermining democratic processes or institutions in Ukraine during the country’s ongoing civil conflict, including the assertion of governmental authority over any area of the country without the authorisation of the Government of Ukraine.
• The programme extends to any entities found to have misappropriated assets owned by the government or economically significant entities in the country.

Trade Restrictions:
• US entities are prohibited from any new investment in the Crimea region, from importing goods from Crimea or exporting US goods there, or providing financial support for such transactions. The same applies to the so-called Donetsk People’s Republic (“DNR”) and Luhansk People’s Republic (“LNR”).
• The direct or indirect provision of goods, technology or services, except financial services, in support of oil exploration or production in deepwater or Arctic offshore areas or shale oil production projects in Russian-controlled territory is also prohibited. US entities are prohibited from engaging in the construction of the Nord Stream 2 and Turkstream pipeline projects and are banned from selling or leasing vessels to participate in the projects.
• Prohibition on investment and trading with the so-called Donetsk People’s Republic (“DNR”) and the Luhansk People’s Republic (“LNR”). Any property in the US belonging to or controlled by those deemed to have operated in the DNR or LNR, been a leader of forces in the territory or have materially assisted the territories is subject to sanctions.

Exemptions

1. OFAC authorises certain transactions under 21 General Licences. The majority of these relate to transactions necessary to maintain or wind down operations or existing contracts with several Russian and Ukrainian entities. In addition, certain transactions are authorised if they are deemed necessary to divest or transfer debt, equity or other holdings in certain blocked parties; derivative products whose value is linked to an underlying asset that constitutes a prohibited debt under the sanctions programme; and certain transactions conducted by financial institutions. With regard to Crimea, authorisations extend to: certain transactions related to telecommunications and mail; internet-based communications; the operation of personal accounts; non-commercial personal remittances; and the export or re-export of certain agricultural commodities, medicine, medical supplies and replacement parts.

2. On 21st February 2022 OFAC released six new General Licenses which prohibit a range of transactions normally falling under its sanctions regime. These include the winding down of transactions involving the DNR and LNR, coronavirus exemptions for the DNR and LNR, some telecommunications and communications exemptions, and exemptions for some remittances and for UN, arbitration and humanitarian organisations.

Links 1

Ukraine-/Russia-Related Sanctions Regulations
Executive Order 13660 - Blocking Property of Certain Persons Contributing to the Situation in Ukraine (06/03/2014)
Executive Order 13661 - Blocking Property of Additional Persons Contributing to the Situation in Ukraine (17/03/2014)
Executive Order 13662 - Blocking Property of Additional Persons Contributing to the Situation in Ukraine (20/03/2014)
Determination Pursuant to Executive Order 13662 (Effective 16/07/2014) - Financial Services and Energy Sectors​
Determination Pursuant to Executive Order 13662 (Effective 12/09/2014) - Defense and Related Materiel Sector
Executive Order 13685 - Blocking Property of Certain Persons and Prohibiting Certain Transactions with Respect to the Crimea Region of Ukraine (19/12/2014)
Executive Order 13849 - Authorizing the Implementation of Certain Sanctions Set Forth in the Countering America’s Adversaries Through Sanctions Act (20/09/2018)
Executive Order 13883 - Administration of Proliferation Sanctions and Amendment of Executive Order 12851 (03/08/2019)
Executive Order 14065 - Blocking Property Of Certain Persons And Prohibiting Certain Transactions With Respect To Continued Russian Efforts To Undermine The Sovereignty And Territorial Integrity Of Ukraine (21/02/2022)
General License 11 - ​Authorizing Certain Transactions With FAU Glavgosekspertiza Rossii (20/12/2016)
General License 18 - Authorizing the Exportation or Reexportation of Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates to Certain Regions of Ukraine and Transactions Related to the Coronavirus Disease 2019 (COVID-19) Pandemic (21/02/2022)
General License 19 - Authorizing Transactions Related to Telecommunications and Mail (21/02/2022)
General License 20 - Official Business of Certain International Organizations and Entities (21/02/2022)
General License 21 - Authorizing Noncommercial, Personal Remittances and the Operation of Accounts (21/02/2022)
General License 22 - Authorizing the Exportation of Certain Services and Software Incident to Internet-Based Communications (21/02/2022)
General License 23 - Certain Transactions in Support of Nongovernmental Organizations’ Activities (11/03/2022)
General License 24 - Transactions Related to the Provision of Maritime Services (18/03/2022)
General License 25 - Journalistic Activities and Establishment of News Bureaus in Certain Regions of Ukraine (24/03/2022)
Update to the List of Medical Supplies for Ukraine-/Russia-Related Sanctions (31/05/2022)

Sanction Name

Restrictive Measures In Response To The Illegal Annexation Of Crimea And Sevastopol

SANCTIONS

Trade Restrictions,

First Imposed

June 23, 2014

Last updated

April 26, 2022

Targets

Trade Restrictions:
• Ban on the importation of goods from or investment in assets in Crimea or Sevastopol. Prohibition of the export to Crimea and Sevastopol of goods and technology for use in the sectors of transport, telecommunications, energy, oil, gas, infrastructure and mineral resources or related services, as well as services related to tourism. Prohibition of certain ships from entering ports in Crimea and Sevastopol.

Sanctions against Venezuela target actions of the government of President Nicolas Maduro restricting civil liberties and repressing popular protests. The US first imposed sanctions against the country in 2014, following government action against protestors. The EU and SECO imposed their own measures in 2017 following actions taken by the government during that year’s Constituent Assembly election. In 2019 the US extended the programme to target the Venezuelan government and state-owned entities to press for the removal of the Maduro government in favour of National Assembly leader Juan Guaido.

On 13th November 2023 the EU renewed its Venezuela sanctions by 6 months until 14th May 2024. The 6 month instead of 1 year extension took place in response to the “positive step towards the restoration of democracy”, following the signing of an electoral roadmap agreement between the opposition political alliance Venezuela’s Unitary Platform and representatives of President Nicolas Maduro.

On 10th November 2023 the EU deleted one entry – Tibisay Lucena Ramirez who died in April 2023 – and amended the statement of reasons for 16 entries, including government officials and military commanders, on its Venezuela sanctions list

Sanction Name

Restrictive Measures In View Of The Situation In Venezuela

First Imposed

November 13, 2017

Last updated

November 14, 2023

Targets

Asset Freeze, Arms Embargo and Travel Ban:
• A ban on the export of arms and equipment which might be used for internal repression, a ban on the export of surveillance equipment and the freezing of funds and a travel ban on those deemed to be responsible for serious human rights violations or abuses; the repression of civil society and democratic opposition; and those who undermine democracy or the rule of law in Venezuela, as well as their associates.

Exemptions

1. Exemptions can be granted on a case-by-case basis on humanitarian grounds or to support the attendance of inter-governmental meetings.

Sanction Name

Ordinance on measures against Venezuela

SANCTIONS

Asset Freeze, Arms Embargo, Travel Ban,

First Imposed

March 28, 2018

Last updated

November 28, 2023

Targets

Asset Freeze, Arms Embargo and Travel Ban:
• A ban on the export of arms and equipment which might be used for internal repression, a ban on the export of surveillance equipment and the freezing of funds and a travel ban on those deemed to be responsible for serious human rights violations or abuses; the repression of civil society and democratic opposition; and those who undermine democracy or the rule of law in Venezuela, as well as their associates.

Exemptions

1. Asset freeze exemptions can be granted to prevent cases of rigor; in respect of existing contracts; to respect credits due under existing judicial, administrative or arbitral judgments; for diplomatic or consular missions; or to protect Swiss interests.

2. Travel ban exemptions may be granted on humanitarian grounds, to support the attendance of international conferences, to participate in political dialogue concerning Venezuela or if the protection of Swiss interests requires it.

On 16th January 2024 OFAC issued Venezuela-related General License 5N authorising certain transactions related to the Petróleos de Venezuela’s 2020 8.5% Bond on or after 16th April 2024.

On 29th January 2024 the US Department of State announced it was reviewing its decision to grant Venezuela certain relief from sanctions in response to the Venezuelan Supreme Court judgement upholding a ban which prevents opposition presidential candidate, Maria Corina Machado, from holding office. OFAC also issued Venezuela-related General License 43A authorising the wind down of transactions involving Venezuelan state-owned gold mining company CVG Compania General de Mineria de Venezuela CA.

On 2nd February 2024 OFAC published an update to FAQs related to the suspension of certain US sanctions with respect to Venezuela on 18th October 2023.

Sanction Name

Sanctions With Respect to the Situation in Venezuela

SANCTIONS

Specially Designated National, Travel Ban, Trade Restrictions,

First Imposed

March 9, 2015

Last updated

March 1, 2024

Targets

Special Designation, Trade Restrictions and Travel Ban:
• Since February 2014 sanctions have been imposed on individuals found to be responsible for or complicit in human rights or political abuses during anti-government protests, or in public corruption by senior officials within the government of Venezuela. The programme also targets current and former leaders of such entities, as well as any entities which have directed or provided support to the activities mentioned above. Under these criteria, on 8th January 2019 OFAC sanctioned seven individuals and companies controlled by them, after they were allegedly involved in a corrupt scheme to take advantage of the Venezuelan Government’s currency exchange practices.

• In January 2018 the sanctions against Venezuela were expanded to include transactions related to digital currencies, coins or tokens issued by the Venezuelan Government, as well as dealings in Venezuelan state debt. In May 2018 sanctions were further expanded to include transactions related to the provision of financing and other dealings in debt owed to the Government of Venezuela or any debt owed to the Venezuelan Government pledged as collateral. In November 2018 sanctions were imposed on Venezuela’s gold sector.

• After Juan Guaido, with backing from the US government, declared himself acting President of Venezuela on 23rd January 2019, OFAC significantly increased the intensity of its sanctions programme to facilitate the removal of President Maduro’s government. To this end, on 25th January 2019, sanctions were imposed on state oil company PDVSA and the Central Bank of Venezuela. Government officials and politicians aligned with Maduro have since been sanctioned, while in March 2019 sanctions were imposed on state-owned ferrous metals mining company CVG Compania General de Mineria de Venezuela CA (“Minerven”) and Venezuelan development bank Banco de Desarrollo Economico y Social de Venezuela (“BANDES”) and four of its subsidiaries.

Exemptions

1. In 2019 a number of general licences were issued to limit the impact of sanctions against Venezuela for US persons and companies. Certain transactions involving three Venezuelan state-owned entities which have a significant presence in the US – CITGO Holding Inc, PDV Holding Inc, Nynas AB and any of their subsidiaries – are authorised.

2. In addition, five entities which have significant existing commercial agreements and contracts with PDVSA – Chevron Corporation, Halliburton, Schlumberger Ltd, Baker Hughes and Weatherford International and their subsidiaries – were authorised to engage in certain transactions with PDVSA until 1st December 2022. US persons in Venezuela are also allowed to purchase refined petroleum products from PDVSA.

3. Similarly, five entities – MasterCard Incorporated, Visa Inc, American Express Company, Western Union Company, MoneyGram International – along with US persons maintaining, operating or closing accounts with BANDES and its four subsidiaries were authorised to complete such transactions.

4. There are also exemptions to protect US and non-US customers with exposure to the Venezuelan banking sector. Transactions related to the provision of financing for and other dealings in certain bonds of the Venezuela Government and PDVSA are authorised as long as they are conducted by a non-US person.

5. Transactions related to US Government official business are also authorised.

6. Transactions with the following Venezuelan government employees are authorised: those who are US citizens, permanent resident aliens, those with valid immigrant or non-immigrant visas or former Venezuelan government employees.

7. In July 2021 OFAC issued General License 5G, authorising US entities to acquire bonds issued by Petroleos de Venezuela. General Licence 5I has now extended the exemption until 20th January 2023.

8. On 20th January 2022 OFAC issued General License 5I, “Authorizing Certain Transactions Related to the Petroleos de Venezuela SA 2020 8.5 Percent Bond”.

9. On 27th May 2022 OFAC issued the Venezuela-related General License 8J, authorising transactions involving Petroleas de Venezuela SA necessary for the limited maintenance of essential operations in Venezuela or the Wind Down of Operations in Venezuela for certain entities.

10. On 7th July 2022 OFAC issued Venezuela-related General License 40A, which authorises certain transactions involving the exportation and reexportation of liquefied petroleum gas to Venezuela.

11. On 26th November 2022 OFAC issued Venezuela-related General License 8K, authorising transactions involving Petroleos de Venezuela SA, necessary for the maintenance of essential operations in Venezuela or the winding down of operations in Venezuela for certain entities. On the same day, OFAC also issued General License 41 authorising certain transactions related to Chevron Corporation’s joint ventures in Venezuela.

12. General License 31B authorises certain transactions involving the IV Venezuelan National Assembly and certain other persons.

13. General License 8L authorises transactions involving Petroleos de Venezuela SA necessary for the limited maintenance of essential operations in Venezuela or the wind down of operations in Venezuela for certain entities. General License 5L authorises certain transactions related to the Petroleos de Venezuela SA 2020 8.5% bond on or after 20th October 2023.

14. General License 42 authorises certain transactions related to the negotiation of certain settlement agreements with the IV Venezuelan National Assembly and Certain Other Persons

15. General License 39B authorises certain activities to respond to Covid-19.

16. General License 40B authorises certain transactions involving the exportation or reexportation of liquefied petroleum gas to Venezuela.

17. General License 5L authorises certain transactions related to the Petroleas de Venezuela SA’s 2020 8.5% bond on or after 20th October 2023.

Links 1

Venezuela Sanctions Regulations
Venezuela Defense of Human Rights and Civil Society Act of 2014
Executive Order 13692 - Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Venezuela (08/03/2015)
Executive Order 13808 - Imposing Additional Sanctions with Respect to the Situation in Venezuela (24/08/2017)
Executive Order 13827 - Taking Additional Steps to Address the Situation in Venezuela (19/03/2018)
Executive Order 13835 - Prohibiting Certain Additional Transactions with Respect to Venezuela (21/05/2018)
Executive Order 13850 - Blocking Property of Additional Persons Contributing to the Situation in Venezuela (01/11/2018)
Determination Pursuant to Executive Order 13850 (Effective 28/01/2019) - Oil Sector
Determination Pursuant to Executive Order 13850 (Effective 22/03/2019) - Financial Sector
Determination Pursuant to Executive Order 13850 (Effective 09/05/2019) - Defense and Security Sector
Executive Order 13857​ - Taking Additional Steps to Address the National Emergency With Respect to Venezuela (25/01/2019)
Executive Order 13884 - Blocking Property of the Government of Venezuela (05/08/019)
General License 2A - Authorizing Certain New Debt, New Equity, and Securities Transactions Involving PDV Holding, Inc. and CITGO Holding, Inc.
General License 3I - Authorizing Transactions Related to, Provision of Financing for, and Other Dealings in Certain Bonds
General License 4C - Authorizing Certain New Debt Transactions and Other Transactions Involving Certain Blocked Persons Related to the Exportation or Reexportation of Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates
General License 5M - Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After January 18, 2024.
General License 7C - Authorizing Certain Activities Involving PDV Holding, Inc. and CITGO Holding, Inc.
General License 8M - Authorizing Transactions Involving Petróleos de Venezuela, S.A. (PdVSA) Necessary for the Limited Maintenance of Essential Operations in Venezuela or the Wind Down of Operations in Venezuela for Certain Entities
General License 9H - Authorizing Transactions Related to Dealings in Certain Securities
General License 10A - Authorizing the Purchase in Venezuela of Refined Petroleum Products from Petróleos de Venezuela, S.A. (PdVSA)
General License 15C - Authorizing Transactions Involving Certain Banks for Certain Entities
General License 16C - Authorizing Maintenance of U.S. Person Accounts and Noncommercial, Personal Remittances involving Certain Banks
General License 18A​ - Authorizing Certain Transactions Involving Integración Administradora de Fondos de Ahorro Previsional, S.A.
General License 21 - Entries in Certain Accounts for Normal Service Charges and Payments and Transfers to Blocked Accounts in U.S. Financial Institutions Authorized
General License 22 - Venezuela’s Mission to the United Nations
General License 23 - Third-country Diplomatic and Consular Funds Transfers Authorized
General License 24 - Certain Transactions Involving the Government of Venezuela Related to Telecommunications and Mail Authorized
General License 25 - Exportation of Certain Services, Software, Hardware, and Technology Incident to the Exchange of Communications over the Internet Authorized
General License 26 - Emergency and Certain Other Medical Services Authorized
General License 27 - ​Certain Transactions Related to Patents, Trademarks, and Copyrights Authorized
General License 29 - Certain Transactions Involving the Government of Venezuela in Support of Certain Nongovernmental Organizations’ Activities Authorized
General License 30A - Authorizing Certain Transactions Necessary to Port and Airport Operations
General License 31B - Certain Transactions Involving the IV Venezuelan National Assembly and Certain Other Persons
General License 32 - Authorizing Certain Transactions Related to Personal Maintenance of Individuals who are U.S. Persons Residing in Venezuela
General License 33 - Authorizing Overflight Payments, Emergency Landings, and Air Ambulance Services
General License 34A​ - Authorizing Transactions Involving Certain Government of Venezuela Persons
General License 35​ - Authorizing Certain Administrative Transactions with the Government of Venezuela
General License 39B - Authorizing Certain Activities to Respond to the Coronavirus Disease 2019 (COVID-19)
General License 40B - Authorizing Certain Transactions Involving the Exportation or Reexportation of Liquefied Petroleum Gas to Venezuela
General License 41 - Authorizing Certain Transactions Related to Chevron Corporation’s Joint Ventures in Venezuela
General License 42 - Authorizing Certain Transactions Related to the Negotiation of Certain Settlement Agreements with the IV Venezuelan National Assembly and Certain Other Persons
General License 43A - Authorizing the Wind Down of Transactions Involving CVG Compania General de Mineria de Venezuela CA
General License 44 - Authorizing Transactions Related to Oil or Gas Sector Operations in Venezuela
General License 45B - Authorizing Certain Repatriation Transactions Involving Consorcio Venezolano de Industrias Aeronáuticas y Servicios Aéreos, S.A.

Sanction Name

Venezuela (Sanctions) (EU Exit) Regulations 2019

SANCTIONS

Asset Freeze, Arms Embargo, Travel Ban,

First Imposed

December 31, 2020

Last updated

August 2, 2022

Targets

Asset Freeze, Arms Embargo and Travel Ban:
• A ban on the export of arms and equipment which might be used for internal repression, a ban on the export of surveillance equipment and the freezing of funds and a travel ban on those deemed to be responsible for serious human rights violations or abuses; the repression of civil society and democratic opposition; and those who undermine democracy or the rule of law in Venezuela, as well as their associates.

Exemptions

1. Exemptions can be granted on a case-by-case basis on humanitarian grounds or to support the attendance of inter-governmental meetings.

UN-led sanctions on Yemen target forces opposing the internationally recognised government of President Abdurabbuh Al Hadi in the country’s ongoing civil war. They have been in place since 2014. A US programme was first instituted in 2012, targeting parties opposing a peace agreement according to which Al Hadi’s predecessor, Ali Abdullah Saleh, left government.

On 14th November 2023 the UN extended its Yemen sanctions regime until 15th November 2024.

Sanction Name

UN Security Council Regulations Against Yemen

First Imposed

February 26, 2014

Last updated

November 14, 2023

Targets

Asset Freeze, Arms Embargo and Travel Ban:
• Entities seeking to disrupt the political transition in Yemen. Includes an embargo on the provision of arms or materiel to such groups.

Exemptions

1. There is an exemption on frozen assets with regards to judicial, administrative or arbitral liens or judgments, as well as on interests, earnings and payments due under contracts, agreements or obligations entered into prior to the listing of a sanctioned party.

2. Travel ban exemptions can be granted on a case-by-case basis where it would further peace and stability in Yemen as well as for humanitarian purposes and the fulfilment of judicial processes.

Sanction Name

Restrictive Measures In View Of The Situation In Yemen

SANCTIONS

Asset Freeze, Arms Embargo, Travel Ban,

First Imposed

December 18, 2014

Last updated

February 16, 2023

Targets

Asset Freeze, Arms Embargo and Travel Ban:
• Individuals deemed to be obstructing the transition of power in Yemen following the 2011 peace agreement. Includes a ban on the supply of arms and related materiel to these entities.

Exemptions

1. Travel ban exemptions can be granted on a case-by-case basis where it would further peace and stability in Yemen as well as for humanitarian purposes.

2. Asset freeze exemptions are permitted for basic expenses, the provision of legal and professional services, fees for the holding of frozen funds and for the satisfaction of judicial, administrative or arbitral liens or judgments.

Sanction Name

Regulation on measures against Yemen

SANCTIONS

Asset Freeze, Arms Embargo, Travel Ban,

First Imposed

December 5, 2014

Last updated

June 1, 2023

Targets

Asset Freeze, Arms Embargo and Travel Ban:
• Individuals and entities undermining the stability of Yemen. This includes those who are involved in human rights abuses, violence against civilians and the recruitment of child soldiers. The programme includes an arms embargo and travel bans.

Exemptions

1. Asset freeze exemptions can be granted to prevent cases of rigor; in respect of existing contracts; to respect credits due under existing judicial, administrative or arbitral judgments; to provide humanitarian aid; or to protect Swiss interests.

Sanction Name

Yemen Sanctions Program

SANCTIONS

Specially Designated National,

First Imposed

May 16, 2012

Last updated

November 18, 2021

Targets

Specially Designated National:
• Entities which have been involved in violence or other acts obstructing the transition of power in Yemen following the 2011 peace agreement and their leaders, as well as those supporting such activity.

On 25th January 2024 the UK and US jointly sanctioned key figures within the Houthi regime. Designations included the Commander of the Houthi Naval Forces and the Houthi Defence Minister, who are both involved in co-ordinating the attacks on international shipping in the Red Sea began in November 2023.

Sanction Name

Yemen (Sanctions) (EU Exit) Regulations 2019

SANCTIONS

Asset Freeze, Arms Embargo, Travel Ban,

First Imposed

December 31, 2020

Last updated

February 27, 2024

Targets

Asset Freeze, Arms Embargo and Travel Ban:
• Individuals deemed to be obstructing the peace, security and stability of Yemen, transition of power following the 2011 peace agreement and those seen as not respecting human rights in the country. Includes a ban on the supply of arms and related materiel to these entities.

Exemptions

1. Travel ban exemptions can be granted on a case-by-case basis where they would further peace and stability in Yemen as well as for humanitarian purposes.

2. Asset freeze exemptions are permitted for basic expenses, the provision of legal and professional services, fees for the holding of frozen funds and for the satisfaction of judicial, administrative or arbitral liens or judgments.

Sanctions were first imposed against Zimbabwe in 2002, in response to political repression conducted by the government of then President Robert Mugabe and extensive political corruption. Mugabe was deposed in a 2017 coup by current President Emmerson Mnangagwa.

On 1st March 2023 the EU extended the sanctions programme for another year.

Sanction Name

Restrictive Measures In Respect Of Zimbabwe

First Imposed

February 18, 2002

Last updated

February 6, 2024

Targets

Asset Freeze and Travel Ban:
•Apply to five individuals – Vice-President Constantine Chiwenga; Perence Shiri, the Minister of Lands, Agriculture and Rural Resettlement; Phillip Sibanda, the Commander of the Zimbabwe Defence Forces; former Zimbabwe Police Commissioner General Augustine Chihuri; senior security figure Happyton Bonyongwe; and Zimbabwe Defence Industries.

Arms Embargo:
• A ban on the supply of arms or related material to the Government of Zimbabwe, although the supply of certain equipment for civilian use in mining or infrastructure projects is authorised.

Exemptions

1. Travel Ban exemptions can be granted on a case-by-case basis on humanitarian grounds or for attending inter-governmental meetings.

2. Asset freeze exemptions are also permitted for basic expenses, the provision of legal and professional services and fees for the holding of frozen funds.

3. The travel ban and asset freeze are not applicable to four persons listed in Annex IV of Council Regulation 2020/213 (see Links)

Sanction Name

Regulation on measures against Zimbabwe

SANCTIONS

Asset Freeze, Arms Embargo, Travel Ban,

First Imposed

March 19, 2002

Last updated

January 1, 2022

Targets

Asset Freeze, Arms Embargo and Travel Ban:
• Senior officials in the government of Zimbabwe and several state-owned enterprises, as well as any other parties found to have engaged in actions or policies which undermine the country’s democratic processes or in human rights abuses relating to political repression. The programme includes a ban on the supply of military equipment and goods that may be used for internal repression.

Exemptions

1. Asset freeze exemptions can be granted to protect Swiss interests.

2. Travel ban exemptions may be granted on humanitarian grounds, to attend international conferences, to participate in political dialogue concerning Zimbabwe or if the protection of Swiss interests requires it.

Sanction Name

Zimbabwe (Sanctions) (EU Exit) Regulations 2019

SANCTIONS

Asset Freeze, Arms Embargo, Travel Ban,

First Imposed

December 31, 2020

Last updated

March 18, 2022

Targets

Asset Freeze and Travel Ban:
•Apply to five individuals – Vice-President Constantine Chiwenga; Perence Shiri, the Minister of Lands, Agriculture and Rural Resettlement; Phillip Sibanda, the Commander of the Zimbabwe Defence Forces; former Zimbabwe Police Commissioner General Augustine Chihuri; senior security figure Happyton Bonyongwe; and Zimbabwe Defence Industries.

Arms Embargo:
• A ban on the supply of arms or related materiel to the Government of Zimbabwe, although the supply of certain equipment for civilian use in mining or infrastructure projects is authorised.

Exemptions

1. Travel Ban exemptions can be granted on a case-by-case basis on humanitarian grounds or for the attendance of inter-governmental meetings.

2. Asset freeze exemptions are also permitted for basic expenses, the provision of legal and professional services and fees for the holding of frozen funds.

3. The travel ban and asset freeze are not applicable to four persons listed in Annex IV of Council Regulation 2020/213 (see Links)

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Alaco is a business intelligence consultancy established in 2002 by industry veterans Amy Lashinsky and Ambrose Carey.

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