In December, the EU adopted its 15th package of sanctions targeting Russia targeting Russia’s shadow fleets and those aiding Russia’s military and technological advancements. The EU’s 16th package, targeting Russia’s hybrid warfare, is rumoured to be announced in February 2025.
Whilst the usual sanctions continued against Russia and Iran, December saw a wave of designations targeting human rights abuses across the globe. Government officials in Georgia were a focus for the US, UK, and EU following a recent increase in violence against journalists and peaceful protestors.
The US announced settlements and fines relating to sanctions evasion and violation of export controls totaling $18.4 million. The US Department of Justice also opened indictments, charging seven individuals for six separate allegations of violating or conspiracy to violate export controls enforced by the US on Russia, the DPRK, China, and Iran.
Russia and Iran
- The EU adopted its 15th sanctions package against Russia. The package targeted 52 vessels from Russia’s shadow fleet and included the designations of 54 individuals and 30 entities. Designations largely related to entities in third countries, notably China, that allow the circumvention of sanctions and indirectly contribute to Russia’s military and technological enhancement. Among other things the package also included a prohibition to recognise certain rulings issued by Russian courts in disputes involving sanctioned parties.
- EU diplomats also reportedly indicated that the EU will announce its 16th sanctions package against Russia in February 2025 to mark the three-year anniversary of Russia’s invasion of Ukraine. This package is said to target individuals involved in disinformation campaigns, cyberattacks, and espionage.
- Sanctions targeting Iran and Russia continued into December. Over the month the US designated 52 entities and vessels for their roles in transporting and trading Iranian petroleum, as well as two entities and two individuals for procuring parts for navigational systems for the Iranian military. The US also targeted two Iran-based entities and one person for contributing to the production of UAVs. The EU carried out its first designations under its Russian hybrid threats framework with the listing of 16 individuals and three entities. The UK specified 20 vessels for transporting Russian oil products and designated two entities for benefitting from and supporting the Russian energy sector. The US designated three entities and amended several listings for involvement in the construction of the Nordstream 2 gas pipeline.
- To end the year, on New Years Eve OFAC sanctioned Russian judge Olesya Mendeleeva for her role in the ongoing detention of human rights activist Alexei Gorinov, and designated one Iranian and one Russian entity for attempted interference in the 2024 US general election.
Updates to Sanctions Regimes
- The EU renewed its sanctions programmes targeting the Democratic Republic of Congo, Guatemala, Mali, and global human rights violations. The US renewed its sanctions regimes for the Taliban and Somalia, as well as its transnational programmes relating to human rights abuses, corruption, and narcotics. With the renewal, the US de-listed 27 from its narcotics programme.
- The EU Parliament adopted resolutions in relation to the respective human rights situations in Crimea, Kyrgyzstan, and Azerbaijan. The resolutions condemned the annexation of Crimea by Russia; highlighted government attacks on freedom of expression, media freedom, and intimidation of political opposition in Kyrgyzstan; demanded that Kyrgyz authorities do not assist Russia in evading sanctions; and condemned Azerbaijan for continued repression of civil society and independent media. The resolutions also called for EU sanctions to be imposed on officials responsible for serious human rights violations in Azerbaijan.
- In the US, the Bureau of Industry and Security (“BIS”) imposed new export controls on several items to Pakistan, which took effect on Boxing Day. The BIS also announced two new resolutions targeting Chinese semiconductors, and renewed the temporary denial of export privileges (TDOs) against Siberian Airlines and Nordwind Airlines for continuing to violate the Export Administration Regulations targeting Russia. The Department of State also announced the creation of a new visa restriction policy under the Immigration and Nationality Act to address wrongful and abusive or unjust detentions.
- The UK and Cyprus agreed to establish a new National Sanctions Implementation Unit in Cyprus. The aim of the unit is reportedly to stop Russian sanctions evasion by sharing information between OFSI, OTSI and the Cypriot Ministry of Finance.
Other Designations
- Global human rights abuses was a key focus for the UK, EU and US in December, with Georgia the primary jurisdiction. The UK designated five Georgian officials said to be responsible for violence against journalists and peaceful protestors in the country, two of whom were also designated by OFAC under its Global Magnitsky human rights regime. OFAC also targeted Georgian Prime Minister Bidzina Ivanishvili whilst the US Department of State (“DoS”) imposed visa restrictions against 20 individuals, including government ministers, law enforcement officials and private citizens. The Vice-President of the European Commission confirmed that the EU had decided to suspend visa-free travel for Georgian diplomatic passport holders in response to Georgia’s newly adopted laws on transparency of foreign influence and for recent violence of peaceful protestors.
- Elsewhere, the US designated three Uzbek government officials alleged to have participated in abuse, sexual assault and trafficking of children in a state-run orphanage, as well as eight individuals and seven entities in Yemen for human rights abuses, arms-trafficking, money-laundering and shipping Iranian oil for the benefit of the Houthis. The DoS also announced visa restrictions for five Russian officials for the forced deportation of Ukrainian children. Meanwhile the EU sanctioned three individuals in Haiti for escalating gang violence and human rights abuses. In Africa, the US and UK targeted gold smuggling. The UK designated five individuals connected with the illicit gold trade, including British-Kenyan businessman Kamlesh Pattni. The US subsequently designated 28 individuals and businesses involved in Pattni’s global gold smuggling network. The EU continued its focus on Sudan, listing four individuals for their involvement in the Rapid Support Forces and two linked to the Sudanese Armed Forces.
- Other designations by OFAC included 12 individuals and 8 entities linked to global narcotics trading, 13 individuals and nine entities under its DPRK, non-proliferation and Russia regimes, and four entities in Pakistan’s ballistic missiles procurement network, as well as a cybersecurity company and one of its employees. OFAC also designated an individual who helped facilitate Bashar al-Assad’s sanctions evasion, as well as four people and four entities in Bosnia and Herzegovina for forming part of Milorad Dodik’s sanctions evasion network. The DoS also listed 14 individuals for significant corruption and one for gross violations of human rights, and imposed visa restrictions on 20 people involved in the misuse of commercial spyware, 17 Russian officials, and seven individuals involved in violence in the West Bank.
- In the EU, December saw the designations of 26 individuals and two entities in Belarus, including members of the judiciary, individuals who have benefitted from Lukashenko’s regime, and the leaders of certain institutions said to be responsible for inhumane conditions and prisoner abuse. The EU also designated Burmese company Royal Shune Lei for acting as an intermediary for Burma’s armed forces in the supply of weapons from the DPRK. The UK designated Irish citizen Brian Sheridan under its counter-terrorism regime for his association with the IRA and financing terrorism.
Enforcement
- December saw the announcements of settlements and fines in the US totalling $18.4 million. The largest was OFAC’s $14.6 million settlement with German industrial equipment supplier Aiotec GmbH for participating in a conspiracy from 2015 to 2019 to cause an unnamed US company to sell an Australian polypropylene plant to Iran, and remit payments for the sale of the plant through US financial institutions. OFAC also agreed settlements with freight brokerage C.H. Robinson International Inc for 82 violations of sanctions against Cuba and Iran, with musical instrument supplier Córdoba Music Group for nine violations of sanctions on Iran, and with technology company SkyGeek Logistics Inc for six violations of Russian sanctions. An unnamed individual also agreed to pay $45,000 to settle six violations of OFAC’s human rights sanctions. The BIS imposed a $3.3 million fine on radio & microwave power engineering and manufacturing company Integra Technologies for 95 violations of export controls on Russia, as well as a $180,000 penalty on Indium Corporation for 11 shipments of electronics manufacturing materials to Russia between April 2022 and March 2023.
- In late November and throughout December the US charged seven individuals for six separate allegations of violating or conspiracy to violate export controls enforced by the US on Russia, the DPRK, China, and Iran. The US Department of Justice (“DoJ”) unsealed an indictment charging Alexey Komov with conspiracy and violations of US sanctions against Russia for allegedly assisting sanctioned Russian Konstantin Malofeyev to recruit and employ an American citizen to launch a television network in Russia. The DoJ also filed a civil forfeiture complaint for $3.4 million in proceeds from the sale of a music studio alleged to be beneficially owned by sanctioned Russian oligarch Oleg Deripaska.
- An international investigation, dubbed Operation Destabilise, into two Russian money laundering networks, ‘Smart’ and ‘TGR’, resulted in 84 arrests and the seizing of £20 million in cash and cryptocurrency. The networks laundered money for criminal organisations and helped individuals bypass sanctions on Russia to invest money in the UK. The operation involved collaboration between authorities in the UK, the US, France, Ireland, and the UAE.
- In Europe, the UK announced a fine of £89,000 against civil aviation training simulator company EDM Limited for exporting military goods without the requisite licence. The Rotterdam District Court found an employee of the Dutch Ministry of Defence guilty of breaching EU sanctions against Russia for exporting aircraft parts to Russia via Kyrgyzstan, Serbia, Tajikistan, Türkiye and UAE. The individual was given a suspended sentence, community service, and director disqualification for 3 years. The Kurzeme District Court in Latvia sentenced the editor of Sputnik Latvija Valentins Rozencovs to 2 years imprisonment for providing services to Russia Today’s director, Dmitry Kiselev, who is designated by the EU. German customs authorities are reportedly investigating a member of Saxon state parliament for breaches of EU sanctions against Belarus for allegedly shipping sanctioned machinery and items to Belarus via Kazakhstan.
- The EU General Court rejected the de-listing applications of two Syrian individuals for familial connections to former President Bashar al-Assad, two Russian individuals, including oligarch Oleg Deripaska, two Russian banks, and two Moldovan government officials. The Court also rejected an application for interim measures by Italian bank Unicredit SPA seeking to suspend part of the European Central Bank’s decision relating to Unicredit’s activities in Russia, and rejected the application of German bank MeSoFa Vermögensverwaltungs AG (“MeSoFa”), formerly Sberbank Europe AG, to annul the European Central Bank’s decision not to grant MeSoFa access to its full assessment of Sberbank Slovenia, including the steps it took to prepare for sanctions. In the US, the US Court of Appeals for the Second Circuit denied state-owned Turkish bank Halkbank’s petition for a rehearing of its Iran sanctions evasion case after the court found Halkbank was not protected from criminal prosecution on foreign sovereign immunity grounds in October 2024.
