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Ross L. Denton

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On 18 October 2017, the “Sanctions and Anti-Money Laundering Bill” (the “Bill”) was introduced into the House of Lords.  According the Government’s press release on the Bill “ensures that when the UK leaves the EU, we can continue to impose, update, and lift sanctions and AML regimes”. A link to the Bill is available here. A link to the Explanatory Notes on the Bill is available here. A link to the Government’s press release regarding the Bill is…

On 17th October 2017, the UK published the Republic of Mali (European Union Financial Sanctions) Regulations 2017 (SI 2017/972) following Council Regulation (EU) 2017/1770. The Council Regulation sets out the EU sanctions on Mali, which are currently limited to restrictions against designated persons, and the UK regulations bring into UK law the enforcement, licensing and penalty provisions for these sanctions.

On October 13, 2017, President Trump announced that he was “decertifying” Iran’s compliance with the Joint Comprehensive Plan of Action (“JCPOA”). By itself, this action does not mean that the United States has withdrawn from the JCPOA, nor does it reinstate sanctions that were lifted under the JCPOA. What it does do, however, is to hand the matter over to the US Congress for a 60-day review period in which Congress must decide whether the sanctions relief under the JCPOA will remain in effect. Congress is also reported to be considering new laws that would automatically re-impose US sanctions if Iran violates existing and new restrictions on its nuclear program and President Trump has threatened to use his authority to cancel US participation in the JCPOA if Congress fails to act. Against this uncertain US political backdrop, both Iran and US allies have reaffirmed their clear commitment to Iran’s compliance with the JCPOA. In parallel, Iran’s Islamic Revolutionary Guard Corps (“IRGC”), which was already designated on the List of Specially Designated Nationals and Blocked Persons (“SDN List”), has been targeted for further sanctions for its support of terrorism, resulting in the loss of certain exemptions under US sanctions.

On 16 October 2017, the EU adopted new measures against the DPRK under Council Regulation (EU) 2017/1858 in response to its continued development of ballistic missiles and nuclear weapons in contravention of UN Security Council resolutions. The regulation implements the following measures: a total ban on EU investment in the DPRK in all sectors; a total ban on the sale of refined petroleum products and crude oil to the DPRK; and lowering the amount of…