Sanctions Top-5 for the week ending 10 April 2020

Here are five things that happened this week in the world of economic sanctions that I think you should know about.

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1. The European Leadership Network (ELN) and The Iran Project released a letter signed by 24 prominent individuals in the US and European national security communities calling for an easing of US sanctions against Iran to help combat the current COVID-19 pandemic. (Read the letter here.) The following day, the US State Department released a fact sheet titled “Iran’s Sanctions Relief Scam,” accusing the Iranian government of using the pandemic in a cynical bid to earn cash.
2. The US Treasury Department, meanwhile, issued a statement emphasizing the “broad exemptions and authorizations” under US sanctions programs for humanitarian-related transactions. (For more on this subject, see my team’s recent advisory on US and EU sanctions policies on humanitarian exports, including an interactive chart of OFAC general licenses.)
3. The US State Department announced the designation of the Russia-based Russian Imperial Movement (RIM) and three of its leaders as Specially Designated Global Terrorists (SDGT) under Executive Order 13224 for providing paramilitary-style training to, and promoting, white supremacists and neo-Nazis in Europe. The RIM has been linked to a 2016 terrorist attack in Sweden, among other nefarious activities.
4. The US Office of Foreign Assets Control (OFAC) published amendments to the North Korea Sanctions Regulations (NKSR) implementing changes from Title LXXI of the National Defense Authorization Act for Fiscal Year 2020 (also known as the Otto Warmbier North Korea Nuclear Sanctions and Enforcement Act). Among other things, the amended regulations prohibit non-US entities owned or controlled by US financial institutions from engaging in certain North Korea-related transactions.
5. The US State Department announced a USD 10 million reward for “information on the activities, networks, and associates of Muhammad Kawtharani” a senior Hizballah official designated as a SDGT in 2013. The reward is offered under the State Department’s Rewards for Justice program.

Comments

The joint ELN/Iran Project letter proposes eight steps the Trump administration could take to increase the flow of humanitarian aid to Iran in light of the COVID-19 outbreak in the country. They include beefing up OFAC’s licensing resources and offering comfort that secondary sanctions would not apply to non-US companies involved in COVID-19-related shipments. The letter argues that the threat posed by the virus to the international community justifies easing the sanctions, while refusing to do so would limit future opportunities for US-Iran diplomacy. “Just because Iran has managed the crisis badly, that does not make its humanitarian needs and our security ones any the less,” the letter argues.

The State Department’s sixteen-point fact sheet — aimed at rebutting “Iran’s slick foreign influence campaign to obtain sanctions relief” — underscores existing exemptions and authorizations allowing US persons to engage in certain exports of humanitarian items and appears to suggest the Iranian government would misappropriate funds meant for COVID-19 relief. The fact sheet also quotes “graffiti in a Tehran suburb” as evidence of internal discontent with the government.

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(The views expressed are my own and do not constitute legal advice. Photo from Vladislav Reshetnyak.)