On March 15, 2018, the US Office of Foreign Assets Control (“OFAC”) added 14 individuals and one entity, the so-called Russian “troll farm” Internet Research Agency LLC (“IRA”), to the Specially Designated Nationals and Blocked Persons List (“SDN List”). OFAC announced a total of 24 designations against persons pursuant to Executive Order (“EO”) 13694 (issued April 1, 2015 and amended December 29, 2016), which is the “Cyber EO” that targets certain “malicious cyber-enabled activities,” and pursuant to Section 224 of the Countering America’s Adversaries Through Sanctions Act (“CAATSA”) , which specifically targets cyber actors who operate on behalf of the Russian government. Nine of the 24 persons identified in OFAC’s announcement were already included on the SDN List. Please see our prior blog post on CAATSA here and prior blog posts on the Cyber EO and its amendment here, here, and here.
On March 1, 2018, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced the amendment and reissuance in their entirety of the North Korea Sanctions Regulations, 31 C.F.R. Part 510 (“NKSR”). A public inspection copy of the Final Rule can be found here. These changes to the NKSR will take effect on March 5, 2018 upon publication in the Federal Register. OFAC also published 13 new FAQs, which can be found here.Read more…
As part of its continuing efforts to isolate North Korea from the world economy, on February 23, 2018, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced new sanctions measures targeting North Korea’s shipping industry and issued an advisory document entitled “North Korea Sanctions Advisory,” which highlights sanctions risks in the global shipping industry.Read more…
On 26 February, the Council of the European Union (the “Council“) announced a number of new and anticipated sanctions measures targeting North Korea, Myanmar/Burma, Cambodia and the Maldives.
The EU has extended its sanctions to fully transpose UN Security Council Resolution 2397 (2017), on which please see our previous blog post available here. The new EU measures include the following:
- a reduction in the total amount of refined petroleum products that may be exported to North Korea from 2 million to 500,000 barrels per year;
- a ban on imports of North Korean food and agricultural products, machinery, electrical equipment, earth and stone, and wood;
- a ban on exports of industrial machinery, transportation vehicles, iron, steel and other metals to North Korea;
- new restrictive measures concerning maritime vessels; and
- a requirement to repatriate all North Korean workers within 24 months (subject to other applicable laws).
The relevant EU legislation is anticipated to be published on 27 February.
The EU has designated two new ministers in the Syrian government, subjecting them to an asset freeze and travel ban. The new Designated Parties are the Ministers of Industry and Information, who were appointed to the Syrian government in January 2018.
In total, the EU has designated 257 individuals and 67 entities in connection with the Syrian regime.
The Council has adopted conclusions in relation to the ongoing human rights situation in Myanmar/Burma, available here. In response to what it refers to as “the continued deterioration of the human rights and security situation”, the Council has recommended:
- an extension of the current embargo on military items, items that may be used for internal repression, and associated services and financing;
- a strengthening of the embargo (although the scope of such strengthening is not set out in the conclusions); and
- targeted restrictive measures against senior members of the Myanmar/Burma military “responsible for serious and systematic human rights violations”.
We will provide an update as and when new measures are implemented.
Cambodia and the Maldives
The Council has also adopted conclusions in relation to the human rights situations in both Cambodia and the Maldives.
The conclusions in relation to Cambodia, available here, urge the Cambodian government to “cease using the judiciary as a political tool”, and note that the Council “may consider specific targeted measures if the situation does not improve”.
As regards the Maldives, the conclusions (available here) call upon the Maldivian government “to immediately lift the State of Emergency, and restore all constitutionally guaranteed rights”. Again, the Council indicates that it may “consider targeted measures” if the situation does not improve.
In each case, the Council does not provide detail as to the scope of the measures that it may consider. We will provide an update if and when the EU implements such measures.