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 European Commission updated its Frequently Asked Questions pages that cover its Russia sanctions regime. The new sections relate to imports and purchase of goods, sale of securities, execution of prior contracts and export-related restrictions. Under the contracts FAQs, the commission addresses what is a contract, whether framework contracts are considered as contracts that benefit from the prior contracts exception to the sanctions regime, and what is an ancillary contract, among other things. The securities FAQs cover whether the sanctions apply to transferable securities issued by private companies and whether the sanctions cover the sale of transferable securities to non-Russian entities that are owned by a Russian national, among other scenarios.
The U.K. amended or corrected a number of entries under several of its sanctions regimes. Under the Syria sanctions list, the Office of Financial Sanctions Implementation amended the entries for Fares Chehabi, president of the Aleppo Chamber of Industry; Khodr Ali Taher, director of Ella Towers; and the Syrian Petroleum Company. OFSI then corrected the entry for Adnan Slakho, former minister for industry. Under the Libya sanctions list, OFSI amended the entry for Khalifa Ghwell, defense minister of the General National Congress. Under the Iran (Human Rights) sanctions list, OFSI amended seven entries. This listings for Ali Khalili, Ali-Akbar Yasaghi, Gholam-Hossein Mohseni-Ejei, Mortez Tamaddon, Mostafa Bozorgnia, Moussa Khalilollahi and Toraj Kazemi were updated, and all of the individuals remain subject to an asset freeze. Four entries under the Chemical Weapons sanctions regime were amended: the agency updated the listings for Vladimir Stephanovich Alexseyev, first deputy head of the GRU, Russia's military intelligence agency; Vladimir Mikhailovich Bogdanov, former director of the Criminalistics Institute and head of the FSB (Federal Security Service) Special Technology Center; Kirill Vasilyev, director of the Criminalistics Institute at the FSB; and Alexei Semenovich Sedov, head of the FSB 2nd Service. All are believed to have been involved in the poisoning of Russian opposition leader Alexey Navalny.
The U.K. in two June 16 notices added entries to its sanctions regimes on Russia and Myanmar. Under the Russia sanctions list, the Office of Financial Sanctions Implementation sanctioned 12 people and corrected one entry. Under the Myanmar sanctions list, OFSI added six entries.
Sanctions regimes over the last 20 years have become broader and more comprehensive, which has created unintended consequences for industry and “ordinary people,” said Erica Moret, a senior researcher at the Geneva Graduate Institute, speaking during a June 16 virtual conference hosted by the Center for a New American Security. She said countries should look to narrow their sanctions measures and provide clear exemptions or risk further over-compliance.
The Bureau of Industry and Security on June 16 suspended the export privileges of Belavia Belarusian Airlines, the country’s state-owned national airline, for violating U.S. export controls against Belarus. BIS issued a 180-day temporary denial order for Belavia, which bans it from participating in transactions subject to the Export Administration Regulations.
The U.K. made took sanctions actions June 14, amending or correcting entries under its Iran (Nuclear), Russia, and ISIL and al-Qaida sanctions regimes. Under the Iran sanctions list, the Office of Financial Sanctions Implementation amended the entry for Parvis Fatah, an officer of the Iran Revolutionary Guard Corps. Under the Russia sanctions regime, OFSI amended 39 entries and corrected an additional three, still subjecting all entries to an asset freeze. The 39 entries consist of 23 individuals and 16 entities and include military officials, businesspeople and media figures. The three corrected entries are for Ilya Kiva, former member of the Ukrainian parliament; Maxim Alekseevich Parshin, member of the Donetsk People's Council; and Ooo Volga Group. For the ISIL sanctions list, OFSI amended listing information for Mochammad Achwan, Taha Ibrahim Abdallah Bakr Al Khuwayt, Amir Muhammad Sa'id Abdal-Rahman Al-Salbi, Mounir Ben Dhaou Ben Brahim Ben Helal, Muhammad Sholeh Ibrahim and Aris Sumarsono.
The Swiss Federal Council announced June 10 that it will adopt the EU's sixth Russian sanctions package, which includes a ban on Russian oil imports. The sanctions package also designates over 100 Russian and Belarusian individuals and entities, making the Swiss sanctions list identical to the EU's; removes four Russian and Belarusian banks from SWIFT, the interbank payment and messaging system; and expands the export ban on goods that could aid Russia's military.
The U.K. released guidance on how it collects data on its Russia sanctions regime. The Foreign, Commonwealth & Development Office published sections on the sanctions' legislation, data collected "post invasion," individual designations, estimates of oligarchs' net worths, oligarchs' family members and sanctions on entities.
The U.K.'s Office of Financial Sanctions Implementation released a General License June 10 permitting certain activity for retail banking services. The license permits non-designated individuals to use retail banking services of a sanctioned Russian or Belarusian credit or financial institution if the payments are made or received are meant for that individual's personal use and the total value of the payments made June 10 to Sept. 10 doesn't exceed $60,000. The license permits such action until Sept. 10. A relevant institution can process these payments, the license said.