On June 14, 2023, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) published a Fact Sheet providing a helpful consolidated summary of the various existing exemptions, exceptions, and authorizations relating to the provision of humanitarian assistance that are available under certain US sanctions programs to respond to the COVID-19 pandemic. The Fact Sheet is informational only and does not supersede any legal obligations or create new, or modify existing, exemptions, exceptions, or authorizations. Fact…
This week in our Sanctions Enforcement Around the World series, we bring you the view from Spain. What are the recent sanctions enforcement trends in Spain? In Spain, fines for sanctions violations are not published but sanctions enforcement actions have been the subject of reports in the press. Generally, the overall sanctions enforcement environment in Spain has not been as active as in other EU Member States. However, in the context of Russia sanctions, there…
Having focused on the enforcement of sanctions by Australia, Ukraine, and Switzerland in the past weeks, we now turn our attention to the sanctions enforcement trends in the Netherlands. What are the recent sanctions enforcement trends in the Netherlands? Recent sanctions enforcement trends in the Netherlands are mainly focused on Russia. Although the Dutch government previously already took a more restrictive (sanctions) policy position towards Russia, this is particularly the case since the Russian invasion of Ukraine last…
On April 27, 2023, the US Department of State (“State”) designated Russia’s Federal Security Service (“FSB”) and Iran’s Islamic Revolutionary Guard Corps Intelligence Organization (“IRGC-IO”) pursuant to Executive Order (“EO”) 14078 (Bolstering Efforts To Bring Hostages and Wrongfully Detained United States Nationals Home), with the result that the IRGC-IO has been added to the Specially Designated Nationals and Blocked Persons List (“SDN List”). The IRGC as a whole and FSB were previously designated on the…