June 17, 2011

August 23, 2024

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

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.

Asset Freeze, Arms Embargo, Travel Ban,

August 5, 2011

April 13, 2022

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

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

Asset Freeze, Arms Embargo, Travel Ban,

September 23, 2001

February 11, 2024

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

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.

Asset Freeze, Arms Embargo, Travel Ban,

December 31, 2020

February 16, 2022

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

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

December 31, 2020

January 10, 2023

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

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.

December 31, 2020

January 10, 2023

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

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.

March 22, 2011

March 25, 2024

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

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

Specially Designated National, Asset Freeze, Travel Ban,

June 27, 2001

June 18, 2024

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.

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.

May 18, 2006

September 13, 2024

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.

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.

Asset Freeze, Travel Ban,

June 28, 2006

August 14, 2024

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.

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.

Specially Designated National,

June 20, 2006

August 9, 2024

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.

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.

Asset Freeze, Travel Ban,

December 31, 2020

October 3, 2024

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, wood, and aluminium.

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.

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.

5. On 29th April 2024 OFSI published a general license amending the fee caps for law firms receiving payments from designated persons to whom they had prior obligations.

March 20, 2012

March 25, 2024

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.

Asset Freeze, Travel Ban,

December 31, 2020

January 15, 2024

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.

October 2, 2015

October 21, 2024

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

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

Asset Freeze,

December 1, 2015

March 15, 2024

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

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.

December 5, 2013

July 30, 2024

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.

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.

Asset Freeze, Arms Embargo, Travel Ban,

December 23, 2013

November 11, 2023

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.

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.

Asset Freeze, Arms Embargo, Travel Ban,

March 14, 2014

March 15, 2024

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.

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.

Specially Designated National, Travel Ban,

May 12, 2014

December 8, 2023

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.

Asset Freeze, Arms Embargo, Travel Ban,

December 31, 2020

June 13, 2024

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.

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.

Trade Restrictions,

June 27, 1989

June 27, 1989

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

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

November 17, 2020

June 1, 2022

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.

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.

Specially Designated National,

July 14, 2020

December 20, 2021

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.

December 31, 2020

April 3, 2024

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.

July 4, 1993

August 27, 2024

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.

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.

July 28, 2003

June 27, 2024

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.

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.

Asset Freeze, Arms Embargo, Travel Ban,

May 23, 2013

July 26, 2024

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.

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.

Asset Freeze, Arms Embargo, Travel Ban,

June 22, 2005

October 23, 2024

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.

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.

Specially Designated National, Arms Embargo,

October 27, 2006

July 25, 2024

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.

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

Asset Freeze, Arms Embargo, Travel Ban,

December 31, 2020

May 17, 2024

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.

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.

September 17, 2021

February 8, 2022

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.

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.

January 12, 2024

February 2, 2024

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.

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

Asset Freeze, Travel Ban,

April 10, 2024

April 10, 2024

Asset Freeze and Travel Ban:
• These measures target senior officials in Guatemala’s judiciary who undermine democracy, the rule of law, and the peaceful transition of power in Guatemala, including by attempting to invalidate the legitimate result of the 2023 presidential elections.

October 21, 2022

October 18, 2024

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.

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 operates 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 established pursuant to resolution 2653 (2022) to further the objectives of peace and stability in Haiti.

Asset Freeze, Travel Ban, Arms Embargo,

November 25, 2022

June 24, 2024

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.

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.

Asset Freeze, Travel Ban, Arms Embargo, ,

December 16, 2022

September 27, 2024

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.

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.

Asset Freeze, Travel Ban, Arms Embargo,

December 28, 2022

October 1, 2024

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.

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.

July 20, 2015

January 23, 2016

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

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.

Asset Freeze,

April 14, 2011

September 13, 2024

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.

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

Asset Freeze, Arms Embargo, Trade Restrictions,

February 27, 2007

September 13, 2024

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.

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.

Asset Freeze, Travel Ban, Trade Restrictions,

July 20, 2023

October 14, 2024

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.

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

Asset Freeze, Arms Embargo, Trade Restrictions,

February 14, 2007

August 16, 2024

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.

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.

Specially Designated National, Arms Embargo, Trade Restrictions,

November 14, 1979

October 17, 2024

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.

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.

Specially Designated National,

August 2, 2017

December 7, 2021

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.

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.

Asset Freeze,

December 14, 2023

October 14, 2024

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.

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

Asset Freeze, Arms Embargo, Trade Restrictions,

December 31, 2020

December 14, 2023

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.

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.

November 24, 2003

October 5, 2023

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.

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.

Asset Freeze, Arms Embargo,

July 7, 2003

September 13, 2024

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.

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.

Asset Freeze, Arms Embargo, Trade Restrictions,

May 22, 2003

October 5, 2023

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.

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.

Specially Designated National, Trade Restrictions,

August 28, 2003

August 23, 2023

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.

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.

Asset Freeze, Arms Embargo,

December 31, 2020

October 6, 2023

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.

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.

October 31, 2005

March 27, 2007

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.

Asset Freeze, Arms Embargo, Travel Ban,

September 25, 2006

September 13, 2024

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.

Asset Freeze,

December 14, 2005

February 16, 2023

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

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

Arms Embargo,

August 11, 2006

January 1, 2022

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.

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.

Asset Freeze, Travel Ban,

December 21, 2005

March 15, 2024

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

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

Specially Designated National,

August 1, 2007

August 10, 2023

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.

Asset Freeze, Arms Embargo, Travel Ban,

December 31, 2020

December 31, 2020

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.

Asset Freeze,

December 31, 2020

December 31, 2020

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

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

February 26, 2011

May 31, 2024

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.

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.

Asset Freeze, Arms Embargo, Trade Restrictions,

March 3, 2011

July 24, 2024

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.

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.

Asset Freeze, Arms Embargo, Travel Ban,

March 30, 2011

August 16, 2024

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.

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.

Specially Designated National, Travel Ban,

February 25, 2011

October 17, 2022

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.

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.

Asset Freeze, Arms Embargo, Trade Restrictions,

December 31, 2020

November 30, 2023

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.

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.

September 28, 2017

April 24, 2024

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.

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

Asset Freeze, Travel Ban,

November 22, 2017

September 1, 2023

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.

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.

Asset Freeze, Travel Ban,

July 26, 2019

August 4, 2023

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.

Asset Freeze, Travel Ban,

December 31, 2020

September 6, 2023

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.

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

September 28, 2010

October 14, 2024

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

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

Asset Freeze, Travel Ban,

June 28, 2023

May 22, 2024

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.

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.

April 26, 2010

October 29, 2024

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.

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.

Arms Embargo, Trade Restrictions,

October 2, 2000

May 14, 2024

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.

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.

,

February 11, 2021

August 20, 2024

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.

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

OFAC also authorises the provision of agricultural commodities, medicine, medical devices, replacement parts and components for medical devices, or software updates for medical devices to individuals whose property and interests in property are blocked pursuant to the Burma Sanctions Regulations

Travel Ban,

December 31, 2020

June 13, 2024

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.

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

Asset Freeze, Travel Ban,

October 15, 2019

October 8, 2024

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.

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.

Asset Freeze, Travel Ban,

May 24, 2020

October 23, 2024

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.

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.

November 27, 2018

May 15, 2024

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.

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.

Asset Freeze, Travel Ban,

December 31, 2020

November 15, 2021

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.

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.

October 23, 2023

October 15, 2024

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.

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.

October 14, 2006

September 17, 2024

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.

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.

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

December 22, 2010

September 13, 2024

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.

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.

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

October 25, 2006

September 18, 2024

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.

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.

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

June 16, 2000

September 19, 2024

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.

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.

Specially Designated National,

August 2, 2018

May 20, 2020

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.

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.

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

December 31, 2020

September 20, 2024

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.

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.

Asset Freeze,

January 19, 2024

July 26, 2024

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.

Asset Freeze, Travel Ban,

April 10, 2024

July 9, 2024

Asset Freeze and Travel Ban:
These measures target individuals and entities that support Hamas or the Palestinian Islamic Jihad (PID) who have committed serious violations of international humanitarian law and international human rights law.

February 1, 2024

October 1, 2024

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, ordering, 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.

October 25, 2010

October 15, 2024

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.

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.

Asset Freeze, Travel Ban,

December 16, 2009

March 15, 2024

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

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.

Asset Freeze, Travel Ban,

December 31, 2020

December 31, 2020

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.

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.

May 18, 2012

February 28, 2018

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

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.

Asset Freeze, Travel Ban,

May 4, 2012

September 25, 2024

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.

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

Asset Freeze, Travel Ban,

June 1, 2012

October 8, 2024

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

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.

Asset Freeze, Travel Ban,

December 31, 2020

March 10, 2022

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.

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

June 23, 2014

June 19, 2024

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.

Trade Restrictions,

February 23, 2022

September 13, 2024

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.

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.

Arms Embargo, Travel Ban, Trade Restrictions,

July 31, 2014

September 13, 2024

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 January 2024, phased in progressively from March 2024, and completed by September 2024.

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.

Asset Freeze, Travel Ban,

March 17, 2014

September 14, 2024

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.

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

Asset Freeze, Travel Ban, Trade Restrictions,

May 27, 2024

May 27, 2024

Travel Ban and Asset Freeze
• Any persons found to engage in internal repression, including, inter alia, torture and other cruel, inhuman and degrading treatment or punishment, summary or arbitrary executions, disappearances, arbitrary detentions and other major violations of human rights and fundamental freedoms, as set out in relevant international human rights instruments, including the Universal Declaration on Human Rights and the International Covenant on Civil and Political Rights.

Trade Restrictions
•The regime imposes certain sectoral restrictions on exporting items which might be used for internal repression, as well as items intended primarily for use in the monitoring or interception of information security and telecommunication.

Asset Freeze, Arms Embargo, Trade Restrictions,

March 6, 2015

October 17, 2024

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.

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.

Specially Designated National, Travel Ban, Trade Restrictions,

March 6, 2014

October 23, 2024

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.

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.

Specially Designated National,

August 2, 2017

September 15, 2022

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.

Trade Restrictions,

March 20, 2014

August 23, 2024

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.

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.

General Licenses 103 and 104 authorise transactions related to imports of certain diamond jewellery prohibited by Executive Order 14068, including importation for admission into a foreign trade zone located in the United States, of diamond jewellery that was physically located outside of the Russian Federation prior to March 1, 2024, and not exported or reexported from the Russian Federation on or after March 1, 2024. Exemptions similarly apply to non-industrial diamonds with a weight of 1.0 carat (provided they have not been not exported or re-exported from the Russian Federation since 1st March 2024) and non-industrial diamonds with a weight of 0.5 carats or greater (provided they have not been exported or re-exported from the Russian Federation since 1st September 2024).

Trade Restrictions,

April 16, 2021

October 30, 2024

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.

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 transactions 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.

13. Transactions related to energy are authorised, meaning the extraction, production, refinement, liquefaction, gasification, regasification, conversion,
enrichment, fabrication, transport, or purchase of petroleum, including crude oil, lease condensates, unfinished oils, natural gas liquids, petroleum products, natural gas, or other products capable of producing energy, such as coal, wood, or agricultural products used to manufacture biofuels, or uranium in any form, as well as the development, production, generation, transmission, or exchange of power, through any means, including nuclear, thermal,
and renewable energy sources.

14. U.S. persons, or entities owned or controlled, directly or indirectly, by a U.S. person, are authorized to pay taxes, fees, or import duties, and purchase or receive permits, licenses, registrations, certifications, or tax refunds to the extent such transactions are prohibited by Directive 4 under Executive Order 14024, 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, provided such transactions are ordinarily incident and necessary to the day-to-day operations in the Russian Federation of such U.S. persons or entities.

15. Transactions related to the wind down of Federal State Unitary Enterprise International Information Agency Rossiya Segodnya; Autonomous Non Profit Organization TV Novosti; or entity in which one or more of the above persons own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest.

16. All transactions necessary to the receipt or transmission of telecommunications involving the Russian Federation that are prohibited by the Russian Harmful Foreign Activities Sanctions Regulations are authorised.

17. Certain transactions involving blocked persons or vessels are permitted in order to ensure the safe docking and anchoring of vessels, the preservation of the health and safety of crew, and emergency repairs or environmental mitigation.

18. Transactions related to energy (meaning extraction, production, refinement, liquefaction, gasification, regasification, conversion, enrichment, fabrication, transport, or purchase of petroleum, including crude oil, lease condensates, unfinished oils, natural gas liquids, petroleum products, natural gas, or other
products capable of producing energy, such as coal, wood, or agricultural products used to manufacture biofuels, or uranium in any form, as well as the development, production, generation, transmission, or exchange of power, through any means, including nuclear, thermal, and renewable energy sources) with a select number of Russian entities (outlined in General License 8K) are permitted.

19. All transactions ordinarily incident and necessary to the receipt or transmission of telecommunications involving the Russian Federation that are prohibited by the Russian Harmful Foreign Activities Sanctions
Regulations are authorised.

Arms Embargo, Travel Ban, Trade Restrictions,

December 31, 2020

October 28, 2024

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.

• 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/2024/4671884 allowed payment of monies owed by designated persons to law firms in the case of prior obligation.

• General License INT/2024/4761108 allows a non-designated third party to make use of designated credit or financial institutions provided payments made or received are for personal use and do not exceed £50,000.

•General License INT/2024/4919848 allows the sale, divestment and transfer of financial instruments held by the National Settlement Depository and payment of safe keeping fees to the National Settlement Depository.

•General License INT/2024/5028385 allows payments relating to the insolvency proceedings of East West United Bank SA to be made, received, and processed.

•The Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2024, amending The Russia (Sanctions) (EU Exit) Regulations 2019 (notice),clarifies that the provision of legal advisory services, which may otherwise be restricted by regulation 54D of the Russia Regulations, are permitted on or in connection with compliance with global sanctions, Russian counter-sanctions and global criminal law. The amendment also clarifies that legal advisory services are permitted in relation to the application of punitive measures, as well as in relation to compliance with UK statutory or regulatory obligations.

April 24, 1992

May 21, 2024

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. 

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.

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

April 27, 2010

June 17, 2024

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.

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.

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

May 13, 2009

May 21, 2024

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.

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.

Specially Designated National, Arms Embargo, Trade Restrictions,

April 13, 2010

May 24, 2023

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.

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

December 31, 2020

June 26, 2024

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.

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.

March 3, 2015

May 30, 2023

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.

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.

Asset Freeze, Arms Embargo, Travel Ban,

May 8, 2015

September 13, 2024

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.

Asset Freeze, Arms Embargo, Travel Ban,

August 12, 2015

June 28, 2024

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.

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.

Specially Designated National, Arms Embargo, Travel Ban,

April 3, 2014

December 8, 2023

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.

Asset Freeze, Arms Embargo, Travel Ban,

December 31, 2020

March 8, 2023

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.

March 29, 2005

September 11, 2024

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.

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.

Asset Freeze, Arms Embargo, Travel Ban,

May 30, 2005

September 13, 2024

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.

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.

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

May 25, 2005

July 9, 2024

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.

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.

Specially Designated National, Trade Restrictions, Arms Embargo,

November 4, 1997

October 24, 2024

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.

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.

Asset Freeze, Arms Embargo, Travel Ban,

December 31, 2020

April 15, 2024

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.

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.

January 8, 2012

September 13, 2024

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.

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.

Asset Freeze,

December 14, 2005

February 16, 2023

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

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.

Asset Freeze, Arms Embargo, Trade Restrictions,

May 18, 2011

October 8, 2024

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.

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.

Specially Designated National, Trade Restrictions,

May 11, 2004

October 16, 2024

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.

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

Specially Designated National,

October 14, 2019

August 17, 2023

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.

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

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

December 31, 2020

July 31, 2024

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.

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.

4. Exceptions related to petroleum products have been extended to include the UN; international and humanitarian organisations; and NGOs. Previously the exception only extended to those funded by the UK government. The amendment requires a person relying on the exception to notify the Treasury rather than the SoS and widens the scope of the exception to apply to the “acquisition”, supply and delivery of petroleum products, as opposed to their “purchase”, supply and delivery; and
amends the record keeping requirements with respect to trade licences.

February 2, 2011

October 9, 2024

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

Asset Freeze, Travel Ban,

November 11, 2019

November 11, 2023

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.

October 14, 2019

August 17, 2023

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.

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

June 23, 2014

June 19, 2024

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.

Trade Restrictions,

February 23, 2022

September 13, 2024

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.

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.