The UK led the way in November 2024 with its largest package of sanctions against Russia in over 18 months. Meanwhile, the US targeted Russia’s banking sector with the designation of Gazprombank and over 50 Russian banks.
Elsewhere the US has focused its designations on corrupt officials in Venezuela, Colombia, and Bosnia and Herzegovina, whilst the UK has started its “campaign to fight dirty money” by designating eight individuals under its global anti-corruption regime. The US also continued its wave of Middle East-focused designations and separately in late November added 29 entities to its Uyghur Forced Labor Prevention Act Entity List.
US regulators and prosecutors were busy in November, with fines totaling over $19.6 million handed down and the imprisonment of several individuals charged with conspiracy to evade sanctions against Russia, Venezuela, and China. The UK also handed down fines totaling £1.98 million, whilst courts in Stuttgart and Rotterdam charged two unnamed defendants with evading EU sanctions.
Russia
- On 7th November the UK announced its largest sanctions package against Russia since May 2023 with 56 designations aimed at targeting Russia’s supply of military equipment in Ukraine and in proxy military groups in Mali, the Central African Republic and Libya. Later in the month the UK carried out its largest package of sanctions against Russia’s “shadow fleet” of oil transporters with the designations of two entities and specifications of 30 ships under its Russia sanctions regime. The UK also sanctioned eight individuals and two entities for alleged involvement in forcible deportations and attempted indoctrinations of Ukrainian children. The UK also removed Didier Casimiro, former VP of Rosneft, from its Russia sanctions list.
- The US carried out similarly far reaching designations this month. OFAC designated Gazprombank, over 50 Russian banks, over 40 Russian securities registrars and 15 individuals. The US BIS also renewed its temporary denial of export privileges against Rossiya for a fourth time to prevent a violation of US export controls.
- The European Parliament has passed a resolution denouncing Iran, Belarus, and North Korea for their military support of Russia. The resolution urges EU Member States to strengthen the sanctions regimes against these countries. It also called on China to end military and dual use assistance to Russia.
Regulations Amendments
- The EU published a notice of its intention to maintain its sanctions against 15 individuals and four entities listed under its DPRK regime. The EU later expanded its sanctions regime against Iran to include prohibitions on: the export, transfer, supply, or sale from the EU to Iran of components used in the development and production of missiles and UAVs; and any transaction with ports and locks that are owned, operated or controlled by listed individuals and entities, or are used for the transfer of Iranian UAVs or missiles or related technology and components to Russia.
- The US extended its sanctions programmes with respect to Iran and Nicaragua for a further 12 months. OFAC also extended executive orders with respect to the threat from securities investments that finance certain Chinese companies, and with respect to the proliferation of weapons of mass destruction. The US amended and reissued its Burma sanctions regulations.
- The US Department of Commerce’s Bureau of Industry and Security (“BIS”) published a final rule imposing new export controls on items to Pakistan. The final rule takes effect on 26th December 2024, from which point exporters will be required to obtain a BIS licence to export, reexport, or transfer items to or within Pakistan.
Other Designations
- The US Department of Homeland Security, on behalf of the Forced Labor Enforcement Task Force, added 29 Chinese companies to the Uyghur Forced Labor Prevention Act Entity List. Goods made in whole or in part in Xinjiang or produced by entities on the UFLPA Entity List are prohibited from import.
- Relating to corruption and allegations of human rights violations, the US designated several individuals around the globe, including 21 senior Venezuelan officials alleged to have supported and carried out Venezuelan President Nicolás Maduro’s repression of the opposition and protestors following the Venezuelan presidential election on 28th July 2024. The US also designated former Colombian General Mario Montoya Uribe for involvement in gross human rights violations, as well as one individual and one entity alleged to support a corrupt patronage network in Bosnia and Herzegovina. Also focusing on anti-corruption, the UK designated 8 individuals on its global anti-corruption list following a government push to campaign against dirty money. The EU announced its intention to maintain sanctions against former Prime Minister of Mali, Choguel Maïga, for his role in postponing elections in the country.
- In the Middle East, OFAC sanctioned 26 companies, individuals, and vessels associated with the Al-Qatirji Company, a Syrian conglomerate responsible for generating hundreds of millions of dollars in revenue for Iran’s Islamic Revolutionary Guard Corps-Qods Force and the Houthis through the sale of Iranian oil to Syria and China. OFAC later designated six individuals for their involvement with Hamas, as well as three entities and three individuals for their roles in violence targeting civilians or in the destruction or dispossession of property in the West Bank. Amana, the largest organisation involved in settlement and illegal outpost development in the West Bank, and its subsidiary Binyanei Bar Amana Ltd were also designated by the UK.
- The EU added one person and four entities linked to Iran-Russia drone shipments to its Iran list including the Islamic Republic of Iran Shipping Line (“IRISL”) and its director Mohammad Reza Khiabani, who is also a director of three Russian shipping companies. The UK also designated IRISL and the Islamic Republic of Iran Airlines, concurrently issuing a general licence permitting certain payments related to Iran Air’s operations. The Council of the EU added three Syrian officials to its Syria sanctions list: the Minister of Internal Trade and Consumer Protection, the Minister of Petroleum and Mineral Resources; and the Minister of State.
- Elsewhere, throughout the last month the US sanctioned 19 Mexican nationals and two Mexican-based entities for involvement in drugs trafficking into the US, as well as connections to the Gulf Cartel. The UN designated two Sudanese Rapid Support Forces commanders under its Sudan programme. The US designated one of them a week later, with the other having already been designated since May 2024.
Enforcement
- US regulators handed down several fines in November. The BIS imposed a civil penalty of $500,000 against semiconductor wafer manufacturing company GlobalFoundries US Inc for shipments of semiconductor wafers without the requisite license, and it reached a settlement with three individuals and their company M&M Wireless Inc (“M&M”) over 94 alleged violations of the Export Administration Regulations. The settlement included the suspension of export privileges for three years, alongside an almost $5.4 million penalty and $460,000 civil forfeiture action that is being brought by the US Customs and Border Protection against M&M.
- OFAC announced two penalties for breaches of Iranian sanctions: a $180,000 settlement with American Life Insurance Company for 2,331 apparent violations by providing insurance policies to UAE entities owned or controlled by the Iranian government, and a $1.1 million penalty against an unnamed individual for implementing a plan to purchase and renovate a hotel in Iran using money sent from the US to Iran. Separately, the US District Court for the District Court of Columbia in a default judgment ordered the forfeiture of almost $12 million of funds associated with the Islamic Revolutionary Guard.
- US prosecutors have charged several individuals with sanctions breaches throughout the month. Relating to Russian sanctions Vadim Yermolenko, a dual US-Russian national and resident of New Jersey, pleaded guilty for his role in a transnational procurement and money laundering network that sought to acquire millions of dollars’ worth of sensitive dual-use electronics for Russian military and intelligence services. E-commerce company Eleview International Inc and two of its executives were charged with conspiring to use evasion schemes to export US dual-use technology to Russia. US, Russian, and Israeli national Ilya Khan pleaded guilty for his role in a transnational scheme to secure and illegally export dual-use semiconductors and other sensitive technology to entities in Russia. Indian citizen Sanjay Kaushik was indicted for conspiring to export controlled aviation components to Russia through India and for making false statements in relation to the export. Finally a US Court sentenced Ukrainian national Stanislav Romanyuk to 33 months imprisonment, followed by three years supervised release for attempting to smuggle a dual-use export-controlled item – a jig grinder – from the US to Russia.
- Not relating to Russian sanctions, US authorities arrested Turkish national Taskin Torlak for allegedly working with co-conspirators to transport oil from Venezuela on behalf of Venezuelan state-owned oil company Petróleos de Venezuela SA (“PdVSA”). A US court also sentenced Venezuelan national George Semerene Quintero to 30 months imprisonment, followed by 3 years supervised release, for his role in a scheme to evade US sanctions imposed on PdVSA. Richard Shih, the founder and former CEO of a California-based logistics company, pleaded guilty to conspiring to violate export laws by shipping goods to designated Chinese companies.
- The UK issued four compound settlements to UK exporters totaling £1.98 million: one relating to breaches of Russia sanctions and three relating to unlicensed exports of military listed goods and dual-use goods. Elsewhere, Polish authorities arrested and charged a German national for brokering and exporting dual-use goods to Russia, in breach of EU sanctions. The Higher Regional Court of Stuttgart also sentenced an unnamed defendant to seven-year imprisonment for selling machinery to a Russian weapons manufacturer in breach of EU sanctions, and the Rotterdam District Court handed down two judgments concerning exports of sanctioned computer goods and software that breach EU Russia sanctions. The defendant was sentenced to 450 days in prison, and the court ordered the confiscation of almost EUR 2 million from the defendant’s company.
- The EU General Court rejected the de-listing of Serbian Bogoljub Karić, who was designated in June 2022 for benefitting from or supporting the Lukashenko regime. The court also dismissed an application by three anonymised individuals for interim measures to suspend a designation under the EU’s Russia sanctions regime.
