While designations there continue – notably with OFAC’s targeting of the Wagner Group and its affiliates – this month has seen fewer new sanctions developments with regard to Russia and a renewed focus on Iran. Both the UK and EU have continued to follow the US in sanctioning political and law enforcement figures responsible for violent crackdown against recent protests in the country.
Elsewhere, the sanctioning bodies of the US, UN and UK announced new designations under their counter terrorism programs and the UK and US marked the second anniversary of the 2021 Myanmar coup with a raft of new listings.
This month also saw the unsealing of multiple indictments in US federal courts related to the prosecutions of alleged co-conspirators in several attempts to evade sanctions on behalf of prominent Russian oligarchs. See below for a full summary.
Iran Updates
- On 23rd January the UK and EU both made multiple designations under their respective Iranian sanctions programs in response to violence against Iranian citizens. The UK added five people and two entities to its Iranian Human Rights program, including the Deputy Prosecutor General, as well as regional law enforcement chiefs, deputies and two affiliated entities – the Basij Resistance Force and the Basij Cooperative Foundation.
- The EU designated 18 people and 19 entities, including political figures from central government and parliament, prominent media figures and IRGC leaders, as well as private companies found to be involved in crackdown on recent peaceful protests. On 31st January, the Iran Aircraft Manufacturing Industries Corporation was added to the EU’s Russian sanctions list due to its alleged involvement in the development and delivery of UAVs to Russia.
- On the same day, OFAC designated the IRGC Cooperative Foundation and all five of its board members, as well as Iran’s Deputy Minister of Intelligence and Security, and four IRGC officers. This followed its decision earlier in that month to impose sanctions on six executives and board members of the already sanctioned Iranian manufacturer of unmanned aerial vehicles, Qods Aviation Industries.
- Designations earlier in the month included the UK’s listing of Iran’s Prosecutor General Mohammad Jafar Montazeri under its Iranian Human Rights program in response to the execution of British-Iranian dual national Alireza Akbari on 14th
- The UK Parliament held a debate in the House of Commons on 12th January on ongoing events in Iran in which the government’s Minister for Europe, Leo Docherty, stated that the government is “actively considering” proscribing the Islamic Revolutionary Guard Corps under the Terrorism Act.
Wagner Group
- On 27th January OFAC announced the imposition of wide-ranging sanctions against the Wagner Group and its associates. Under its Harmful Foreign Activities of the Government of the Russian Federation program, the US has designated ten individuals, including three members of the country’s Penitentiary Service over alleged involvement in the recruitment of prisoners, as well as Russia’s Deputy Prime Minister and five entities, including the Moscow Officers Union for International Security, over alleged ties to the private paramilitary organisation.
- Separately, OFAC designated the Wagner Group and seven allegedly affiliated entities in Russia, China, Luxembourg, and the UAE as a significant transnational criminal organisation pursuant to its activities in Ukraine and the Central African Republic under its transnational program.
Sanctions Enforcement Updates
- On 13th January naturalised US citizen Behrouz Mokhtari pleaded guilty in a federal court in Maryland to two separate counts of conspiracy to violate US sanctions on Iran regarding the exportation, or sale of goods, technology, or services. According to his plea, between March 2018 and September 2020 Mohktari used a network of Iran and UAE-based businesses to which he had links to engage in US dollar transactions involving petrochemical products. The second count of conspiracy, concerned Mokhtari’s work through various companies between February 2013 and June 2017, to facilitate the purchase and maintenance of LPG tanker vessels used to transport petrochemical products on behalf of entities associated with the Iranian government.
- On 23rd January an indictment was unsealed in the Southern District of New York charging former FBI agent Charles McGonigal and Russian translator Sergey Shestakov with money laundering and five counts of conspiring to violate and evade sanctions. It is alleged that the pair worked for US-sanctioned Oleg Deripaska, investigating a rival oligarch in return for concealed payments.
- Californian entrepreneur Tao Jian, and his company, Broad Tech System Inc, have pleaded guilty to violation of the Export Control Act in relation to a scheme whereby Jiang and Broad Tech provided US-manufactured chemicals essential to the manufacture of microchips to the China Electronic Technology Group Corporation 55th Research Institute, a Chinese state-owned and US-sanctioned entity. Jian pleaded guilty to knowingly submitting false invoices and misleading documentation to the US government and shipping companies to conceal the ultimate destination of the goods.
- On 20th January indictments were unsealed in a US federal court in DC charging UK national Richard Masters and Russian/Swiss dual national Vladislvav Osipov with facilitating sanctions evasion and a money laundering scheme in relation to the ownership of a luxury yacht owned by Viktor Vekselberg. Osipov is accused of designing a structure of shell companies to conceal Vekselberg’s ownership of the yacht, meanwhile Masters is the proprietor of a Spain-based company which managed the yacht. Both are accused of using false names to conceal the ultimate beneficiaries of payments from US financial institutions.
Other Updates
- On 31st January, and to coincide with the second anniversary of the 2021 Myanmar coup, the UK and US designated multiple government entities, military officials and military-affiliated logistics companies under their respective Myanmar programs.
- On 6th January OFAC added four individuals and two entities linked to the ISIS to its counter terrorism program. ON 16th January the UN Security Council ISIL and Al-Qaida Sanctions Committee designated Abdul Rehman Makkir, the deputy Amir of Lashkar-e-Taiba and head of its political affairs wing. First designated by the US in November 2010, the UK and Switzerland followed the UN in also designating Makkir this month. On 24th January OFAC designated Lebanese national Hasasn Moukalled under its counter terrorism program for allegedly having played a key role in enabling Hezbollah to exploit and exacerbate Lebanon’s economic crisis.
- On 6th January the release of the EU Commission’s 2023 Work Programme contained a commitment that the EU will update its “sanctions toolbox to include corruption”. The document commits to establishing a sector specific framework targeting corruption in the send quarter of 2023. The Work Programme also contained general commitments to continue coordinating with allies to ensure the effective enforcement of sanctions to maintain strong economic pressure on Russia.
