Sanctions Top-5 for the week ending 24 July 2020

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

Sign up here if you would like to receive these summaries by email. Click here for an index of past Sanctions Top-5 briefings.

1. The US Office of Foreign Assets Control (OFAC) named two Venezuelan brothers as Specially Designated Nationals (SDNs) under Executive Order 13692 for their support of the Nicolás Maduro government and Maduro’s son, Nicolás Ernesto Maduro Guerra. According to the OFAC news release, Santiago Jose Moron Hernandez and Ricardo Jose Moron Hernandez conduct business on behalf of Maduro Guerra and also facilitated the sale of Venezuelan gold.
2. The US Commerce Department’s Bureau of Industry and Security (BIS) added 11 Chinese companies to the Entity List for being “implicated in human rights violations and abuses” in China’s Xinjiang Ughur Autonomous Region (XUAR). The targets include textile and apparel makers accused of using forced labor in the XUAR.
3. The US State Department issued a US visa ban on the leader of the Chechen Republic, his wife, and his daughters under Section 7031(c) of the Department of State, Foreign Operations, and Related Programs Appropriations Act, 2020. According to the State Department announcement, Ramzan Kadyrov “is responsible for numerous gross violations of human rights dating back more than a decade, including torture and extrajudicial killings.”
4. The US Department of Justice (DOJ) announced the extradition from Cyprus of two individuals, including a Lebanese national accused of laundering drug proceeds on behalf of Hezbollah. According to the DOJ news release, the Lebanese individual was arrested after arriving at Cyprus’ Larnaca International Airport in March 2019.
5. Reuters reported that 43 United Nations Member States filed a complaint to the Security Council committee on North Korea sanctions alleging that North Korea has exceeded the annual cap on importation of refined petroleum set in Security Council Resolution 2397 (2017) of 22 December 2017.

Comments

Bonus item: The US Court of Appeals for the Second Circuit upheld the conviction of Turkish banker Mehmet Atilla, who was released from US federal prison in July 2019 after serving time for helping a client process Iran-related transactions through the US financial system. While upholding the conviction, the Court also ruled that the lower court should not have instructed Atilla’s jury that trying to avoid the imposition of US secondary sanctions constituted a violation of the International Emergency Economic Powers Act (IEEPA), as argued by US prosecutors. (Read the decision here.) In another case, the US Southern District dismissed charges against an individual who had been found guilty of violating Iran-related sanctions after prosecutors withheld exculpatory evidence. (My colleagues at Steptoe were his defense lawyers — bravo to them!) (Read about the case here.)

The HM Treasury’s Office of Financial Sanctions Implementation (OFSI) released its Maritime Guidance yesterday. More on this next week.

Curious how new Hong Kong-related sanctions will affect your compliance program? Join Gem Conn, Dow Jone’s Vice President for Risk & Compliance Research, and me for a free webinar hosted by Dow Jones Risk & Compliance on Tuesday, 4 August 2020, at 3:00 p.m. Hong Kong time. Register here.

Did I miss something? Send me a message or comment on LinkedIn.

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