A senior Treasury Department official urged banks in the United Arab Emirates to look out for Russia-related sanctions evasion attempts, warning they could face steep penalties for poor due-diligence. Wally Adeyemo, Treasury’s deputy secretary, said the banks must be “exceedingly cautious in handling any Russia-related businesses.”
Liability under the U.K.'s Russia sanctions regime may be determined even when an offending party wasn't aware of or had no reasonable suspicion of the breach, so companies should review their internal sanctions compliance to ensure they have "comprehensive processes and procedures in place" to avoid sanctions risk, global law firm Sidley Austin said in a guidance.
The U.K. updated its guidance on the sanctions relating to the provision of insurance and reinsurance services over aviation and space goods and technology to a person or entity connected with Russia or for use in Russia. The Office of Financial Sanctions Implementation said that the restrictions "would not apply where the insurance is for the benefit of the non-Russian owner of the items, rather than their user or operator. It also doesn't apply where the items either remain in Russia as the result of the termination of a lease and against the lessor’s will or are flown out of Russia in the process of returning them to their owner.
The Financial Action Task Force recently updated its list of jurisdictions with “deficiencies” in combating terrorism financing, weapons proliferation and other sanctions-related issues, the Financial Crimes Enforcement Network said June 23. The FATF removed Malta from the list of jurisdictions under increased monitoring and added Gibraltar. It didn’t make any changes to its list of “High-Risk Jurisdictions Subject to a Call for Action,” which includes countries subject to “extensive” U.S. sanctions, such as North Korea and Iran.
DOJ plans to expand its work with Ukraine to help it combat Russia sanctions evasion, the agency said this week. The agency will specifically send Ukraine an “expert” DOJ prosecutor to “advise on fighting kleptocracy, corruption, and money laundering” and will deploy two additional attorneys from the Office of International Affairs to support the department’s KleptoCapture Task Force. The lawyers will work “closely” with their EU counterparts and Middle Eastern countries to “facilitate mutual legal assistance and extraditions relating to Russian illicit finance and sanctions evasion, including with respect to designated Russian oligarchs who have supported the Russian regime and its efforts to undermine Ukrainian sovereignty,” DOJ said.
U.S.-EU cooperation on export controls, sanctions and other trade issues bodes well for the future of multilateral cooperation, said Rupert Schlegelmilch, a senior trade official with the European Commission, speaking during a June 22 event hosted by the Atlantic Council. Schlegelmilch specifically praised the work of the Trade and Technology Council’s export control working group (see 2206010007 and 2205160033), which allowed both sides to respond quickly to Russia’s invasion of Ukraine in February.
The EU renewed until June 23, 2023, its sanctions regime over Russia's annexation of Crimea and the city of Sevastopol, the European Council announced June 20. Originally introduced in 2014, the restrictions' sectoral sanctions include import bans on goods originating from Crimea or Sevastopol into the EU and financial investments from the affected areas. The council also barred the export of certain goods and technologies to Crimean companies or for use in Crimea.
The EU added three people and one entity to its terrorist sanctions regime, since the parties were linked to al-Qaida's operations in the Sahel region, the European Council announced June 20. The entries are Sidan Ag-Hitta and Salem ould Breihmatt, senior officials with the al-Qaida affiliate Jama'at Nusrat al-Islam Wal-Muslimin, along with the terrorist group's Burkinabe branch Ansarul Islam and its leader Jafar Dicko. The council said the sanctioned parties are responsible for terrorist attacks against civilians at home and in Mali and Burkina Faso, and contribute to the expansion of the terrorist group throughout Western Africa.
The Center for a New American Security last week published an overview of the international sanctions strategy against Russia, including potential escalatory steps, enforcement so far and potential evasion tactics. The post also includes a breakdown of the sanctions by target and sector, detailing the number of sanctions that have been used to punish Russian elites compared to the country’s defense, transportation, financial, technology and energy sectors.
The Office of Foreign Assets Control on June 17 removed a Venezuelan-related entry from its Specially Designated Nationals List. The agency removed Carlos Erik Malpica Flores, who was designated in 2017 for being the former national treasurer and former vice president of finance for Petroleos de Venezuela, the country’s state-run energy company. OFAC didn’t immediately release more information on the delisting.