Sanctions Top-5 for the week ending 20 November 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 US Office of Foreign Assets Control (OFAC) named 51 Iranian entities and 10 individuals as Specially Designated Nationals (SDNs) under Executive Order 13876 for their connections to Iran’s supreme leader. According to a Treasury Department news release, the entities are controlled by the Islamic Revolution Mostazafan Foundation (a.k.a. Bonyad Mostazafan).
2. In related news, the US State Department imposed a US visa ban against two Islamic Revolutionary Guard Corps officials and their immediate family members under Section 7031(c) of the Department of State, Foreign Operations, and Related Programs Appropriations Act of 2020. According to a State Department statement, the officials oversaw the “violent suppression of protests by security forces” in Iran’s Khuzestan province in November 2019.
3. OFAC named one Russian and one North Korean entity as SDNs under Executive Order 13722 for their roles in exporting forced labor from North Korea to work in Russia’s construction sector.
4. The US State Department designated two leaders of Somalia-based al-Qa’ida affiliate Al Shabaab as Specially Designated Global Terrorists (SDGTs) under Executive Order 13224. According to a State Department statement, the targets include the group’s “senior explosives expert” and the mastermind of a January 2020 attack in Kenya that killed a US soldier and two contractors.
5. The European Union is preparing a third round of sanctions in response to the situation in Belarus, including sanctions on “institutions, enterprises and firms,” EU Foreign Minister Josep Borrell said in a press conference. Meanwhile, North Macedonia, Montenegro, Albania, Iceland, Liechtenstein, Norway, and Ukraine have aligned with the EU’s Belarus-related sanctions, according to an EU declaration. (For context, Belarus is just a little smaller than Michigan.)

Comments

Another week, another Iran sanctions update. (Newly ascertained) President-elect Biden has signaled his intention to reenter he Joint Comprehensive Plan of Action (JCPOA) with Iran (among other agreements). Secretary of State Mike Pompeo last week warned in a statement that easing of Iran sanctions would be a “dangerous choice” and said the United States would continue to “impose new sanctions on Iran, including using our nuclear, counterterrorism, and human rights authorities” in the “coming weeks and months.”

After four years of heaping on sanctions, it will be interesting to see which ones the Biden administration could offer to bring Iran back to the negotiating table. There are lots to choose from. At the same time, Tehran could demand a premium, if not a guarantee the sanctions will stay lifted. What do you think? Does the United States need Iran’s OK to reenter the JCPOA? Will the Biden administration use its leverage to demand new concessions? Would Iran get a better deal or a worse one under a hypothetical JCPOA 2.0?

I’m looking forward to talking later today about detecting sanctions circumvention at the virtual AML/CTF Annual Summit hosted by Fintelekt and the Philippines Anti-Money Laundering Council. Checkout the details of the five-day program at this link.

Happy Thanksgiving!

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