Sanctions Top-5 for the week ending 30 April 2021

  1. The UK unveiled a Global Anti-Corruption sanctions regime targeting bribery and misappropriation of property involving public officials. According to an explanatory memorandum from the Foreign, Commonwealth and Development Office, the regime is part of the UK government’s wider anti-corruption strategy and aims “to protect democratic values and promote effective governance.” The UK Foreign Secretary inaugurated the regime by announcing sanctions against 22 individuals in Russia, South Africa, South Sudan, and Latin America.
  2. In coordination with the UK announcement, the US Office of Foreign Assets Control (OFAC) named two former Guatemalan government officials as Specially Designated Nationals (SDNs) under the Global Magnitsky Sanctions program. The US State Department imposed visa bans on them in June 2020.
  3. OFAC announced a USD 34,329 settlement with a major US-based money service business for violations of several OFAC regulations. According to the settlement notice, some of the violations related to money transfers processed on behalf of SDNs held in US federal prisons. (Imagine being in prison and being on the SDN List!)
  4. OFAC announced a USD 2,132,174 settlement with a German software company for violations of the Iranian Transactions and Sanctions Regulations (ITSR). According to the settlement notice, the company sold software from the United States with knowledge it would be re-exported to Iran and made US-based cloud services available to persons in Iran in violation of the ITSR. The US Department of Justice (DOJ) concurrently announced a non-prosecution agreement with the company.
  5. OFAC issued an administrative notice about the conversion of the Non-SDN Communist Chinese military company (CCMC) List from a PDF format to the standard SDN List format. (Fun fact: OFAC’s version of the list still does not include the CCMCs identified by the Department of Defense on 14 January 2021. Check for yourself using OFAC’s online search tool.)




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