Sanctions Top-5 for the week ending 27 August 2021

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 G7 (Canada, the EU, France, Germany, Italy, Japan, the UK, and the United States) may consider adopting coordinated sanctions targeting the Taliban in Afghanistan at a meeting today, according to reports.
2. The US Office of Foreign Assets Control (OFAC) named three individuals and five entities as Specially Designated Nationals (SDNs) under the Global Magnitsky Sanctions program (Executive Order 13818) in connection with corruption in Paraguay. According to a Treasury Department news release, the individuals run a complex, multinational money laundering operation and pay bribes to local government officials.
3. OFAC announced a USD 2,329,991 settlement with the UK subsidiary of a Chinese bank for historical violations of the (defunct) Sudanese Sanctions Regulations. According to the OFAC settlement notice, the bank self-identified 11 transactions processed through the US financial system on behalf of parties in Sudan between 2014 and 2016.
4. OFAC announced a USD 862,318 settlement with a Romanian bank and its US-based parent company for violations of OFAC’s Iran and Syria sanctions regulations. According to the OFAC settlement notice, the bank processed transactions through the US financial system on behalf of parties in Iran and Syria. Then, after the US parent acquired the Romanian bank, the bank processed a EUR payment for persons in Iran. (Remember, non-US entities owned or controlled by US persons are subject to OFAC’s Iran sanctions regulations.)
5. OFAC extended General License M under the Iranian Transactions and Sanctions Regulations (ITSR) until 1 September 2022 and updated related FAQ 853. The new General License M-1 authorizes US persons to export certain graduate-level educational services and related software to students in Iran who are unable to attend classes in the United States during the pandemic.

Comments

The developments in Afghanistan have thrown up a lot of questions about how current or future sanctions against the Taliban could impact the country’s economy and humanitarian aid. Check out this piece by Brian O’Toole at the Atlantic Council for some background on UN sanctions and this piece by Adam Smith at Just Security for some background on US sanctions related to the Taliban.

You might also be interested in this Foreign Policy piece by Paul Massaro concerning the Biden administration’s ongoing top-down sanctions policy review. Although sanctions have a spotty record of changing their targets’ behavior, “. . . sanctions have increasingly — and increasingly successfully — been used to target, upend, and dissolve networks of malign figures: of kleptocrats and oligarchs and organized crime organizations around the world,” Massaro writes.

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