European officials are concerned that a sudden increase in exports of washing machines, refrigerators and other items to Russian neighbors are being used to help the country acquire semiconductors and evade export controls, Bloomger reported Oct. 29. Armenia imported more washing machines from the EU during the first eight months of this year than the last two years combined, the report said, and Kazakhstan imported more than triple the amount of refrigerators through August compared with the same period last year. European officials are concerned some of the items' components may be used by Russia's military, the report said, and have publicly said they have seen parts from fridges in Russian military equipment used in Ukraine.
The Office of Foreign Assets Control has updated its Frequently Asked Questions to give additional guidance regarding the transport of Russian crude oil prior to the implementation of the oil price cap. FAQ 1094, issued Oct. 31, explains that Russian-origin crude oil loaded onto a vessel for maritime transport prior to Dec. 5 will not be subject to the price cap (also known as the “maritime services policy”) provided that the oil is unloaded at the port of destination prior to 12:01 a.m. EST, Jan. 19, 2023.
The Bureau of Industry and Security recently posted a written version of its Oct. 13 live briefing on its new China-related export controls (see 2210130009 and 2210070049). The document includes BIS's rationale for imposing the new restrictions, an overview of what the license requirements cover and some "general" questions and answers.
The Bureau of Industry and Security published its first set of frequently asked questions on its new China-related export controls (see 2210070049), covering the definition of semiconductor “facility” and offering guidance on certain U.S. persons requirements, license review policies and more.
The U.K. Solicitors Regulation Authority in October released its "Anti Money Laundering annual report 2021-22," finding that 26% of the SRA-reviewed anti-money laundering policies implemented by 224 firms failed to mention steps a fee earner should take to ensure that a client is not subject to financial sanctions. The report said the consequences of noncompliance are high, given the Office of Financial Sanctions Implementation's aggressive enforcement. It said compliance can be ensured via correctly identifying sanctioned individuals and entities, avoiding providing listed individuals and entities with prohibited services and ensuring all reporting obligations are fulfilled. SRA said it will boost its sanctions compliance work in the upcoming year.
The U.K.'s Office of Financial Sanctions Implementation updated its frozen assets reporting template, OFSI said. The U.K. Treasury requires all individuals who "hold or control funds or economic resources belonging to a designated person, to complete the reporting form and submit it to" OFSI by Nov. 11. The reporting exercise is conducted annually to update OFSI's records.
The EU General Court in an Oct. 26 judgment annulled the sanctions listing of Dmitry Ovsyannikov under the Russia sanctions regime. The European Council said that given his former positions in the Russian government since 2017, Ovsyannikov undermined Ukraine's sovereignty. The General Court said the council could not justify this finding because Ovsyannikov resigned as Sevastopol governor in 2019 and stopped working as a deputy minister in 2020. The EU had to show that his links with the government since these dates justified his designation -- something the bloc failed to do, the court held. However, Ovsyannikov is still sanctioned following a European Council decision in September that was taken up after the hearing in this case.
The U.K.'s Office of Financial Sanctions Implementation imposed two general licenses under its Russia sanctions regime. The Securing Energy for Europe license lets an individual or entity grant a category five loan or enter into an arrangement to grant this loan to Gazprom Germania or any of its subsidiaries. These loans can be issued for over-the-counter gas trading, payments of credit arrangements and invoices by Gazprom or any of its subsidiaries, customer credit arrangements, the provision of clearing services to Gazprom or any of its subsidiaries, payment between Gazprom or any of its subsidiaries, or the provision of financing for letters of credit. The license will run 11:59 p.m. Oct. 28 to 11:59 p.m. Oct. 29, 2023. The Loans and Securities amendment, which runs 11:59 p.m. Oct. 28 to 11:59 p.m. Nov. 5, permits an individual or entity to directly or indirectly enter into an arrangement to grant a category five loan, though it does not permit activity that would otherwise be permitted under the Securing Energy for Europe license.
The State Department recently added five people as Specially Designated Global Terrorists, according to a notice released Oct. 28. The designations apply to: Mohamed Mire, Yasir Jiis, Yusuf Ahmed Hajji Nurow, Mohamoud Abdi Aden and Mustaf 'Ato, leaders of the sanctioned al-Shabaab group.
The Office of Foreign Assets Control last week imposed sanctions on 15 Khordad Foundation, an Iranian organization responsible for the bounty on author Salman Rushdie. 15 Khordad Foundation has "committed millions of dollars" toward a bounty on the author since 1989 and has raised the bounty amount several times, most recently to $3.3 million, OFAC said in an Oct. 28 news release. The foundation, along with other Iranian entities, has led to the death and injury of several people associated with Rushdie, including writers, translators and publishers, OFAC said.