Sanctions Top-5 for the week ending 21 January 2022

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 four individuals as Specially Designated Nationals (SDNs) under Executive Order 14024 for allegedly carrying out destabilizing activities in Ukraine on behalf of Russia’s Federal Security Service. According to a Treasury Department news release, the targets include an individual who controls several news outlets used to “denigrate senior members of Ukrainian President Volodymyr Zelenskyy’s inner circle” and publish “false assertions about US political candidates.”
2. OFAC named three individuals and a travel company as Specially Designated Global Terrorists (SDGTs) under Executive Order 13224 for allegedly acting as financial facilitators for Hizballah in Lebanon. According to a Treasury Department news release, the targets have helped Hizballah gain “access to material and financial support through the legitimate commercial sector” and exploit Lebanon’s economic resources.
3. In related news, OFAC named three individuals and ten companies in Lebanon, Germany, and Zambia as SDGTs under Executive Order 13224 for allegedly operating an international commercial network used to raise and launder funds on behalf of Hizballah. According to a Treasury Department news release, one of the individuals is the business partner of an individual named as a SDGT earlier in the week (see above).
4. Human Rights Watch published a letter from France’s TotalEnergies stating that the company “supports the implementation” of targeted sanctions against financial flows from certain energy projects in Myanmar involving Myanma Oil and Gas Enterprise (MOGE). According to a Human Rights Watch news release, the company’s statement came in response to a December 2021 letter “urging the company to support sanctions to stop gas payments to Myanmar military-controlled entities.” Both TotalEnergies and Chevron have announced their withdrawal from projects in Myanmar due to the deteriorating political situation in the country.
5. A group of 13 nongovernmental organizations (NGOs) including the International Rescue Committee published a statement urging members of the Economic Community of West African States (ECOWAS) to commit to humanitarian exceptions to a wide-ranging package of Mali-related sanctions announced earlier this month. The ECOWAS “sanctions will have devastating consequences for the people and the humanitarian situation in Mali,” according to the group’s statement. (For more on the ECOWAS sanctions, see last week’s Sanctions Top-5 briefing here.)

Comments

Recent events in Myanmar and Mali underscore the growing influence of NGOs in the sanctions-making process. NGOs play a role by gathering evidence and promoting new sanctions, helping to identify targets for sanctions, advocating for humanitarian exceptions, and drawing attention to sanctions that harm vulnerable peoples. Their work is reflected in the US Treasury Department’s recent 2021 Sanctions Policy Review as well as recent Afghanistan-related general licenses and numerous SDN designations under the Global Magnitsky Sanctions program. They are also helping to inform the actions of corporations, as demonstrated by Human Rights Watch’s interactions with TotalEnergies last week.

Check out the latest issue of FISC Journal edited by Ian Bolton, from the publisher of WorldECR. There’s an interview with the International Compliance Association’s Ross Savage and a lot more. (Shout out to my colleagues at Steptoe for their piece on the very interesting Ali Sadr case.)

Speaking of great resources, UK Finance is hiring a Sanctions Policy Manager. Check out the job posting here.

Coming up in a bit: I’ll be speaking with HashKey Group’s Angelina Kwan, Refinitiv’s Michael Meadon, and Regulation Asia’s Brad Maclean about Russia/Ukraine, China, cryptocurrency, and more, at the APAC Financial Crime Outlook 2022 webinar hosted by Refinitiv on Tuesday, 25 January, at 10:00 a.m. Hong Kong time. Details and registration here.

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