Effective as of 25 November 2023, Ukraine introduced two new sets of personal sanctions against 147 individuals and 303 legal entities (“Sanctions”), in particular:[1] (a) the following Russian companies: Military-industrial enterprises: JSC “Duks”, JSC “Design and Production Enterprise ‘Iris'”, JSC “Okenit”, JSC “Moscow Design Industrial Complex ‘Universal'”, etc. Machine building enterprises: JSC “Gavrilov-Yamsky Machine Building Plant ‘Agat'”, JSC “Machine-Building Plant ‘Armalit'”, etc. Energy companies: JSC “United Energy Company”, JSC “Vologda Regional Energy Company”, JSC “Moscow Regio ..read more

On November 2, 2023, the United States government issued new Russia-related sanctions targeting more than 200 individuals and entities. OFAC also issued three new Russia-related General Licenses and reissued another one, and the US Department of Commerce Bureau of Industry and Security (“BIS”) added 13 entities to the Entity List. SDN Designations The US Department of the Treasury Office of Foreign Assets Control (“OFAC”) and the US Department of State added a range of targeted individuals and entities in Russia, Turkey, the United Arab Emirates, China, and other countries to the Specially Des ..read more

The UK Office of Financial Sanctions Implementation (“OFSI”) and the Foreign, Commonwealth and Development Office (“FCDO”) have issued joint guidance (“Joint Guidance”) on the application of the UK’s “ownership and control” test under financial sanctions legislation in circumstances involving designation of public officials. The Joint Guidance follows a significant amount of debate in relation to these issues, following the Court of Appeal’s recent judgment in the case Mints v PJSC National Bank Trust [2023] EWCA Civ 1132. The Mints judgment included far reaching comments about the role of Vla ..read more

On November 6, 2023, the Department of Commerce’s Bureau of Industry Security (“BIS”) and the Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) published a joint notice (“Joint Notice”) to announce  a new Suspicious Activity Report (“SAR”) key term for financial institutions when reporting possible attempts by entities or individuals to evade US export controls. This builds on similar efforts by BIS and FinCEN to require SARs for transactions related to transactions that may be involved in evasion of export controls targeting Russia. Continued cooperation betwee ..read more

On November 10, 2023, Canada announced additional amendments to the Special Economic Measures (Russia) Regulations (the “Regulations”). The amendments list an additional 9 individuals and 6 entities under Schedule 1 of the Regulations and took effect on November 9, 2023. The Canadian Minister of Foreign Affairs, the Honourable Mélanie Joly, stated that the sanctioned persons and entities “directly promote Russia’s war of aggression against Ukraine” via their participation in Kremlin-backed disinformation and war propaganda to legitimize the war through narratives framed as expert opinion. Curr ..read more

On October 31, 2023, the US, UK, and Canadian governments imposed further coordinated sanctions against Myanmar (Burma) through designations of individuals and entities associated with Myanmar’s military regime and a US prohibition on the provision of financial services to Myanma Oil and Gas Enterprise (“MOGE”). The measures aim to prevent the Burmese military from obtaining access to arms and other supplies and are part of an effort to unify sanctions measures on Myanmar across the US, EU, UK, and Canada. US Financial Services Restrictions and Designations The US Department of the Treasury’s ..read more

In keeping with tradition, we are pleased to invite you to our annual Global Year-End Review of Import/Export & Trade Compliance Developments Conference to be held between December 4-7. The conference will provide valuable insights on the latest developments, challenges and opportunities in the ever-changing landscape of international trade. We will kick off the conference with an in-person networking session and panel discussion on December 4 on the pressing topic of “Navigating Trade Compliance Amidst Geopolitical Disruptions to the Globalized Economy,” to set the stage for our su ..read more

Please check out Episode 9 of the Compliance Podcast of the Caracas office in which Jesus Davila talks to Washington DC partner, Alex Lamy, concerning the US sanctions system over the Venezuelan government and the latest decision regarding the suspension of the sanctions for the hydrocarbons and mining sectors. Alex explains the implications thereof and how this could bring new opportunities for the aforementioned sectors.  A link to the podcast series is available here.  Links to our previous posts about these developments are available in English and Spanish. The post Compliance Po ..read more

On 25 October 2023, the Australian Government published two new designations (see here and here) (Designations) introducing new goods export sanctions for Russia and specified regions of Ukraine (being the Crimea, Sevastopol, Donetsk and Luhansk regions). Under the Designations, the following goods have been designated as “export sanctioned goods”: inter changeable tools for hand tools or machine-tools (for example, for pressing, stamping, punching, tapping, threading, drilling, boring, broaching, milling, turning or screw driving), including dies for drawing or extruding metal, and rock dril ..read more

On 23 October, the European Council adopted a new framework for restrictive measures against Niger which seek to “sanction those who undermine the stability, democracy, rule of law in Niger, and constitute a threat to peace and security in the region” in response to the July 2023 military coup in Niger. The sanctions consist of asset freezes, and the related prohibition to make funds available to targeted individuals and entities, as well as travel bans for certain individuals. In addition, and in order to further humanitarian aid efforts, a humanitarian exception to the asset freeze measures ..read more