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Sanctions Regimes

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On April 12, 2021, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued four amended Frequently Asked Questions (“FAQs”) related to submissions made pursuant to the Trade Sanctions Reform and Export Enhancement Act of 2000 (“TSRA”), as well as the Sudan Program and Darfur Sanctions. We summarize these FAQs below. FAQs Concerning TSRA FAQs 97 and 98 clarify the process for obtaining a TSRA license, as follows: FAQ 97 provides…

The European Commission has removed sanctions placed on six Iraqi state entities under Council Regulation (EC) No 1210/2003, effective from 23 April 2021. The entities include the Iraqi State Export Organisation as well as the Iraqi State Import Organisation. This mirrors the UN Security Council’s decision to remove the entities from its sanctions list on 15 April 2021.

On 19 April 2021, the EU announced further Myanmar sanctions coming into force immediately, adding 10 further individuals to its sanctions list. These 10 individuals were targeted for the positions they hold as members of the State Administrative Council and, unlike previous rounds of designations, do not appear to be military or police officials. This brings the total number of sanctioned individuals to 35 (see our previous blog post here). The Council has also imposed…

On April 1, 2021, President Biden revoked Executive Order 13928 “Blocking Property of Certain Persons Associated with the International Criminal Court” (the “ICC EO”), which authorized the imposition of sanctions and visa restrictions on non-US ICC officials. The US Treasury Department’s Office of Foreign Assets Control concurrently removed two senior ICC officials from the Specially Designated Nationals and Blocked Persons List (“SDN List”), including Fatou Bensouda, the ICC’s chief prosecutor. The ICC EO was signed…