Hong Kong Exchanges and Clearing (HKEX) has published updated guidance on the listing of applicants engaging in activities linked to countries and entities that are subject to sanctions. The guidance talks about timely disclosure of sanctions impact, risks to assist investors, cases in which an issuer’s suitability would become problematic or where HKEK may not give the listing approval because of sanctions.
The Department of International Trade and Institute of Export & International Trade are holding 2 events:
A webinar to introduce the ‘Export Control Profession’, a new professional body focused on exports, imports and trade sanctions compliance taking place between 14:00 and 15:00 on 2 May 2019. Registration and information here.
The London Export Control Symposium will take place on 30 May 2019 at the Park Plaza Hotel, Westminster Bridge, London. Topics include ‘trading in a changing world’ and the launch of the ‘Export Control Profession’. Details and registration here.
The European Union has renewed its sanctions regime on Myanmar/Burma for 1 year until 30 April 2020. The sanctions comprise asset freezes and travel bans on 14 people for serious human rights violations against the Rohingya population and civilians in Rakhine, Kachin and Shan States. The sanctions also impose an embargo on arms and equipment that can be used for internal repression, an export ban on dual-use goods for use by military and border guard police, restrictions on equipment for monitoring communications, and a prohibition on military training and cooperation. See EU Council Press Release.
OFAC has published regulations to implement Executive Order 13848, which declared a national emergency in September 2018 in response to foreign interference in US elections. It authorised sanctions against any foreign government, entity and individual that authorises, directs, sponsors, or otherwise supports US election interference (see previous post). The regulations take effect from 29 April 2019. There will soon be regulations setting out interpretations, definitions and general licences. OFAC Notice.
OFAC has imposed asset freezing measures and a travel ban on two individuals determined to be current or former officials of the Venezuelan government: Jorge Alberto Arreaza Montserrat, the Venezuelan Minister for Foreign Affairs, and Carol Bealexis Padilla de Arretureta, the judge in charge of the First Special Court of First Instance in Control Functions, pursuant to Executive Order 13692, as amended. The US indicated they “will continue to target corrupt Maduro insiders” who “are tasked with conducting diplomacy and carrying out justice on behalf of this illegitimate regime”. See OFAC Notice and Treasury Press Release.
RUSI is hosting an event on 28 May 2019 to launch its Taskforce on the Future of UK Sanctions Policy, composed of former officials, academic and policy experts, who will provide recommendations on UK sanctions policy post-Brexit over the next 12 months. The initiative is supported by Peters & Peters Solicitors LLP, and more details can be found here.
Secretary of State Mike Pompeo has published two notices in the Federal Register regarding sanctions imposed on the Iranian Revolutionary Guard, designated as a foreign terrorist group in early April (see previous post). The first states that the IRGC sanctions will not apply to “any ministry, department, agency or division” in any foreign government, meaning officials will not be subject to US travel bans for having engaged in activity with IRGC or affiliated entities, unless the entity is subject to other US sanctions. The second states that “any business, organisation, or group, whether public or private” (Notice 2) will not be not subject to a US travel ban for “provision of material support” to the IRGC and affiliated entities .
The decision was taken in light of “foreign policy and national security interests” following global attention on the US’ latest sanctions on Iran, including the Trump administration’s recent decision not to renew sanctions waivers for states importing Iranian oil (see previous post).
OFAC has announced a $75,375 settlement with Haverly Systems to settle its potential civil liability for two apparent violations of the Ukraine Related Sanctions Regulations. According to OFAC, between May 2016 to January 2017, Haverly transacted or dealt in new debt of greater than 90 days maturity of JSC Rosneft, a Russian energy firm identified on the Sectoral Sanctions Identifications List (see previous post). For fuller details of the settlement see OFAC Notice and Enforcement Information.
Canada’s Foreign Ministry has announced its fourth round of Venezuela sanctions against 43 individuals “most of whom are high level officials of the Maduro regime” implicated in “systematic erosion of Venezuela’s democratic institutions and its grave human rights abuses” pursuant to Special Economic Measures (Venezuela) Regulations. As a result, these individuals will be subject to asset freezing measures and a dealings prohibition. See overview of sanctions.
OFAC has designated Wael Bazzi and Hassan Tabaja for acting as conduits for Hizballah sanctions evasions schemes, pursuant to Executive Order (E.O.) 13224. Three entities, BSQRD Ltd (British-based), OFFISCOOP NV, and Voltra Transcor Energy BVBA (both Belgium-based), all under the control or ownership of Mr Bazzi, have also been designated. OFAC has also added Energy Engineers Procurementand Construction as an alias for Global Trading Group, one of Mr Bazzi’s already-designated companies.
Wael Bazzi is listed “for acting for or on behalf of Mohammed Bazzi” (who is his father, himself designated as a Specially Designated Global Terrorist in May 2018 (see previous post)) in Gambia and the oil industry. Hassan Tabaja is listed “for acting for or on behalf of Adham Tabaja”, his brother, a designated Hizballah financier, and for acting as his legal and business representative. See OFAC Notice and Treasury Press Release.