This month has seen a continued focus both on Russia and Iran. The UK has added a raft of new Russian political and military figures to its Russia list, meanwhile the US and EU have targeted the support networks involved in exporting Iranian UAVs in support of the Russian invasion, with the EU also fulfilling its parliament’s earlier commitment to target those responsible for the poisoning of Alexei Navalny.
The ongoing protests in Iran – and the government’s crackdown in response – have been the focus of further OFAC, OFSI and EU designations in their relevant programmes on the country, notably including senior staff of Iran’s state broadcaster and certain regional military and political figures. OFAC has also used its Iran program to target front companies enabling the trade of Iranian crude and the organization which maintains a bounty on author Salman Rushdie.
Elsewhere, this month has seen a host of new anti-terror designations by the US, as well US and UK responses to recent North Korean ballistic missile tests.
Russia
- On 30th November the UK added 22 people to its Russian sanctions list, including Deputy Prime Minister Denis Manturov, as well as ten governors and regional politicians, five military commissars, three election officials, two electoral chairs and the chair of the Central Asian Society of Uzbeks of the Perm Territory. Earlier in the month, OFSI had also designated four additional oligarchs – Alexander Abramov, a former non-executive director at Evraz PLC, its former CEO Alexander Frolov, Airat Sahimiev, a former CEO of a Russian state owned construction company and Albert Kashafovich, the CEO of an energy technology manufacturer.
- On 16th November OFAC designated the Shahed Aviation Industries Research Center, Success Aviation Services FZC and I Jet Global DMCC for their involvement in the network of predominantly Iranian entities which has been procuring UAVs for Russian forces fighting in Ukraine.
- This month the EU designated 10 individuals and one entity linked to the poisoning of Alexei Navalny, as well as mirroring the US in designating two individuals and two entities for their involvement in the development and delivery of UAVs to Russia.
- On 4th November the latest amendments to OSFI’s Russia program, covered in previous updates, were laid before parliament and successfully passed. The legislation has brought forward the implementation date for import bans of Russian oil and oil products to 5th December and prohibits the supply or delivery by ship, or the provision of additional professional services to facilitate the supply, of Russian 2709 and 2710 oil from Russia to any third country.
Iran
- On 23rd November OFAC designated three Iranian security officials in response to the ongoing suppression of protests in Iran, and in the Kurdistan region in particular. Also related to the protests was the designation earlier in the month of six senior employees of Islamic Republic of Iran Broadcasting, the country’s state-run media corporation which has broadcast the confessions of arrested Iranian protesters.
- OFAC also added 13 companies to its SDN list for their involvement in the facilitation of the sale of Iranian petrochemicals and petroleum products to buyers in East Asia on behalf of sanctioned Iranian brokers, including the National Iranian Oil Company. On 3rd November OFAC designated the Iranian 15 Khordad foundation, which maintains a bounty on author Salman Rushdie in support of the fatwa issued by former Ayatollah Ruhollah Khomeini in 1989.
- On 14th November the EU designated 29 individuals and three entities linked to the death of Mahsa Amini, as well as officials linked to the violent response to recent demonstrations. On the same day, the UK added 24 people to its Iranian sanctions list, under the human rights program.
Other designations
- On 20th November OFAC designated La Nueva Familia Michoacana, Johnny Hurtado Olascoaga and Jose Alfredo Hurtado Olascoaga for having engaged in the international proliferation of illicit drugs or their means of production, as well as three others on 9th November for supplying illicit fentanyl and other synthetic drugs into US markets.
- On 9th November OFAC designated two individuals involved in transportation and procurement activities on behalf of North Korea, acting on behalf of Air Koryo, a previously designated North Korean transport company. Two days later, the UK added 44 to entries to its North Korean sanctions program.
- On 8th November the EU designated 19 individuals and one entity in relation to human rights abuses in Myanmar, including the Minister of Investment and Foreign Economic Relations and the Chief Justice of the Supreme Court and high-ranking members of the Myanmar military.
- On 7th November OFAC designated four members of an ISIS cell in South Africa which was providing financial technical and material support to the group. OFAC also designated four unrelated entities for being owned, controlled or directed by individuals previously sanctioned under the program. Earlier in the month, OFAC designated six people and 17 entities and blocked eleven vessels, which together comprise an international oil smuggling network which facilitated oil trades and generated revenue for Hezbollah and IRGC under its counterterrorism program. The key figures were Ukrainian national Viktor Artemov, and a series of front companies he operated, and Iranian nationals Edman Nafieh and Rouzbeh Zahedi, who worked at Gila Tar Karvan International Company, which was also sanctioned.
- On 6th November President Biden signed a new Executive Order creating a new authority in respect of OFAC’s Nicaragua sanctions program to sanction certain people to have operated in the gold sector in the country and to prevent US investment in that sector.
- On 4th November the US designated the sitting President of the Haitian Senate, Joseph Lambert, and his predecessor Youri Latortue.
News
- On 28th November, the EU Council unanimously adopted a decision which adds violation of EU sanctions to the list of ‘EU Crimes’ under the Treaty of the Functioning of the CEU. The Commission will now propose a directive containing minimum rules for the definition of what the criminal offense will entail and what the penalty will be.
- OFSI has published its Annual Review of 2022, which revealed inter alia that from 22nd February to 22nd October, £18.39 billion in frozen funds were reported to OFSI as being held on behalf of people designated on the UK’s Russia sanctions program, up from £44.5 million in September 2021. OFSI received 236 reports of sanctions breaches. The number of staff at OFSI will increase, according to the report, to 100 by the end of 2022.
- OFSI Director Giles Thomson is reported to have told the Solicitors Regulation Authority Compliance Officers Conference on November 23rd that some law firms are under investigation by the UK National Crime Agency and OFSI over alleged involvement in breaches of UK sanctions, caveating that it remained a “very small minority” of firms.
- It was reported on 9th November that Jersey police have admitted to conducting unlawful searches on premises allegedly owned by Roman Abramovich. The search warrants were granted by the Jersey Court on application by the Jersey Police Economic Crime and Confiscation Unit, although it is unclear on what grounds the searches were subsequently deemed unlawful.
