EU amends and maintains certain Mali & Venezuela listings
The EU has issued notices for the attention of certain individuals designated under its Mali & Venezuela regimes. The notices inform the individuals that the EU intends to maintain their designations but with amended statements of reasons. Those listed have until 1 November 2024 (Mali) and 4 November 2024 (Venezuela) to apply to obtain the new statement of reasons.
EU renews Burundi sanctions
The EU has renewed its restrictive measures against Burundi for a further year. The sanctions are now set to last until 31 October 2025.
The EU also published the following to reflect the change:
- a notice drawing attention to the data the EU holds of people designated under its Burundi regime
- a notice explaining the procedure for requesting that a listing under the Burundi regime is reconsidered.
EU makes Iran designations over missile transfers
The Council adopted 14th October restrictive measures against seven individuals and seven entities following Iran’s missile and drone transfers to Russia. This decision follows the indication by the European Council in March 2024 that, were Iran to transfer ballistic missiles and related technology to Russia for use against Ukraine, the EU would be prepared to respond swiftly, including with new and significant restrictive measures.
This designation includes individuals and entities responsible for the development and transfer of unmanned aerial vehicles (UAVs), missiles and related technology to Russia in support of its war of aggression against Ukraine, and to armed groups and entities undermining peace and security in the Middle East and the Red Sea region.
The listings include three Iranian Airlines (Saha Airlines, Mahan Air and Iran Air), and two procurement firms. These are respectively responsible for the transfer and supply, through transnational procurement networks, of Iran-made UAVs and related components and technologies to Russia, to be used in its war of aggression against Ukraine. Two companies involved in the production of propellant used to launch rockets and missiles were also listed.
EU designations for destabilising Moldova
The Council adopted 14th October restrictive measures against five individuals and one entity responsible for actions destabilising the Republic of Moldova. Restrictive measures under this regime now apply to a total of 16 individuals and 2 entities.
EU renews chemical weapons sanctions
The EU has renewed its restrictive measures against the proliferation and use of chemical weapons. The regime has been extended for another year until 16 October 2025. Currently 25 persons and 3 entities are listed under the regime.
EU amends renews sanctions
The EU has amended its restrictive measures regime against ISIL (Da’esh) and Al-Qaeda to implement changes made by the UN in June 2024. The amendment clarifies that the designating criteria also include planning, directing or committing acts involving sexual and gender-based violence, including rape, enslavement, abduction and people trafficking. The EU has also renewed its restrictive measures against the leadership of the Transnistrian region of the Republic of Moldova until 31 October 2025.
EU renews Guinea & Niger sanctions
The EU has renewed its restrictive measures regimes against Guinea and Niger. Both have been extended for a further year. The sanctions against Guinea are now set to expire 27 October 2025. Those against Niger are extended until 24 October 2025.
European anti-fraud agency arrests and seizes cargo in Spain for unlawful exports to Russia
Following joint investigations by the European Anti-Fraud Office (OLAF) and Spanish authorities, 4 people have been arrested (3 are Russian) and 13 tonnes of chemicals seized. The investigation revealed that a Spanish company managed by Russian nationals had exported sanctioned chemical products to Russia.
EU Establishes New Framework for Restrictive Measures in Response to Russia’s Destabilizing Actions
The Council of the EU has enacted Regulation (EU) 2024/2642 on 8 October 2024 concerning restrictive measures in view of Russia’s hybrid, destabilizing activities (“EU Russia Destabilization Sanctions”). The new sanctions framework aims at targeting individuals and entities involved in hybrid activities that undermine the fundamental values and security of the EU, its member states, and international organizations. The EU Russia Destabilization Sanctions effectively provide new grounds for the designation of persons or entities as EU designated parties, in addition to the existing designation grounds in EU sanctions regimes, in particular on the basis of Regulation (EU) 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine. Link
New EU anti-money laundering authority AMLA
The EU Authority for Anti-Money Laundering and Countering the Financing of Terrorism (AMLA) was established in June 2024. It is an EU agency that will coordinate with national authorities over anti-money laundering and countering terrorist financing. AMLA’s answers to FAQs say it will:
- “check compliance with sanctions-related measures by the riskiest cross-border groups in the financial sector”
- “contribute to a common supervisory approach to verification of compliance with sanctions-related requirements” and
- “provide critical input to the understanding and mitigation of risks of sanctions evasion/non-implementation” at EU level.
While AMLA was legally established in June 2024, it is not due to start operations until 2025. Link
EU Commission publishes guidelines for cyber-surveillance exporters
Commission published guidelines on the export of cyber-surveillance items, aiming to raise awareness of the risks associated with misuse of cyber-surveillance technologies and provide exporters with practical tools to evaluate human rights. The guidelines include details on:
- The relevant provisions that control cyber-surveillance exports;
- Conducting due-diligence through transaction screening;
- How to assess whether the items exported could pose a risk for human rights violations;
- The possible uses of different cyber-surveillance items; and
- What items fall under “cyber-surveillance”.
French prosecution of Lafarge over sanctions violations to proceed to trial
Judges have ordered the trial of French cement group Lafarge over terrorism financing and sanctions violations. In 2018, Lafarge was placed under investigation over payments that were allegedly made to terrorist groups, including ISIS.
Finnish sanctions investigation
Finnish Customs is investigating a Finnish company over suspected sanctions violations. The unnamed company is said to have exported €700k worth of sanctioned electronics to Russia. The suspected violations occurred in 2022 and on several occasions. Finnish Customs also reported that it has launched more than 800 investigations into sanctions violations.
Germany raids over car exports to Russia
The Bonn Public Prosecutor’s Office and the Essen customs Investigation Department are investigating the owner of a German car dealership over suspected export violations. The unnamed individual is said to have sold and transported many vehicles to Russia. The value of the goods exported is estimated at over €4m. 2 properties were searched in September 2024 and vehicles and an account were seized. The investigation remains ongoing.
Germany arrest for Russia sanctions violations
German police have arrested a man in Nuremberg over suspected sanctions violations. He is said to have violated the Foreign Trade Act through using his Germany-based company to procure maritime goods for final use in Russia. The unnamed suspect allegedly acted as part of an international network. 6 properties have been searched as part of the investigation.
German customs confiscate luxury cars in Russia sanctions investigation
Essen customs and the Würzburg public prosecutor's office are investigating the owner of German car dealership suspected of violating the Foreign Trade Act. The man is said to have exported over €10m-worth of luxury vehicles to Russia. In September 2024, customs searched several properties in Aschaffenburg and confiscated 8 vehicles worth c. €1.5m. Cash and bank balances were also seized.
HMRC compound settlement for breaches of export control
In August and September 2024, HM Revenue and Customs (HMRC) issued compound settlement offers to 3 UK exporters worth £1.9 million. These settlements relate to unlicensed exports of Military listed goods, Dual-Use goods and related activity controlled by The Export Control Order 2008 and Retained Regulation 428/2009.
HMRC compound settlement for breaches of Russian sanctions
HM Revenue and Customs (HMRC) has issued a compound settlement offer to a UK exporter of just over £58,000.00.
- August 2024 - £58,426.45 was paid relating to the export of goods in breach of The Russia (Sanctions) (EU Exit) Regulations 2019
Following Russia’s illegal invasion of Ukraine, the UK and our international partners have implemented the most severe package of sanctions ever imposed on a major economy, which has deprived the Russian state of over $400 billion in funding for its war machine. Failure to comply with these sanctions is a serious offence and those who breach them may be subject to a range of enforcement actions, including large financial penalties or referral for criminal prosecution.
Latvia sanctions enforcement update
Latvia’s State Revenue Service (VID) has initiated 94 criminal proceedings relating to violations of Russia/Belarus sanctions in 2024. These proceedings bring the total number of criminal proceedings initiated in Latvia since sanctions were imposed to over 300.
VID has also suspended 2400 customs procedures in 2024. The exports to Russia/Belarus that VID most frequently prevented involved cars, tractors and electrical equipment.
Norwegian sanctions investigations
The Norwegian Police Security Service (PST) is currently investigating 37 cases concerning Russia sanctions violations. There is also 1 case of a possible Export control Act breach.
Sanctions fine upheld in Netherlands
In case ROT 22/3917, the Rotterdam District Court has upheld a fine on an unnamed trust services producer. The Dutch National Bank (DNB) imposed a €95k on the provider in 2022 following a 3-year investigation. The DNB found that the provider had failed to conduct an audit.
SECO: Ordinance in relation to the situation in Moldova
On 7 November 2024, the Federal Department of Economic Affairs EAER has amended the annex of the Ordinance instituting measures in relation to the situation in Moldova. Five individuals and one entity have been added to the annex. The measures come into force at 6 pm on 8 November 2024. Link
SECO: Ordinance on measures against the Islamic Republic of Iran
On 6 November 2024, annexes 1a and 6a of the ordinance on measures against the Islamic Republic of Iran were amended. 13 individuals and 11 entities have been added to annex 6a. In addition, the content of the list of goods in annex 1a of the ordinance has been completed. The measures come into force on 7 November 2024. Link
SECO - Ordinance on measures against the Democratic Republic of Congo
On 22 October 2024 the Federal Department of Economic Affairs EAER has amended annex 2 to the ordinance on measures against the Democratic Republic of Congo. The entries concerning two individuals have been modified. The modifications come into force at 6 pm on 23 October 2024. Link
Ship commander acquitted in France of sanctions violations
The commander of the vessel Baltic Leader has been acquitted of sanctions violations in France. His trial commenced in September 2024 over transporting wind turbines on a Russian-flagged ship.
New UK legal services General Licence for Russia & Belarus
The UK’s Legal Services General Licence (GL) for Russia & Belarus, due to expire on 28 October 2024 will be replaced with the new General Licence INT/2024/5334756.
The new GL contains the following key changes from the current GL:
- expands the definition of a law firm and applies the GL financial limit “per law firm”;
- includes a definition of a non-UK bank account;
- increases the amount of professional legal fees that can be paid from £500k to £2m;
- increases the expenses that can be paid to £200k or 10% of the legal fees payable, whichever is the lower; and
- permits payments to be paid directly to a Non-UK Bank Account, subject to certain conditions.
The previous licence expires at 23:59 on 28 October 2024. The new licence takes effect from 00:01 29 October 2024 and is set to expire in April 2025.
UK amends counter-terrorism sanctions guidance
The UK has amended its counter-terrorism sanctions: guidance to include director disqualifications. In June 2024, the Sanctions Regulations 2024 came into force which allowed the relevant Minister to impose director disqualification sanctions in relation to the counter-terrorism regime.
The new guidance:
- explains that the effect of director disqualification sanctions is to make it an offence for designated persons to act as a director of a UK company;
- states that Companies House is responsible for preventing registration of disqualified directors;
- states that a breach of director disqualification sanctions is an offence under the Company Directors Disqualification Act 1986; and
- advises that designated individuals should not act as a director without the requisite licence.
Ukraine: Switzerland adopts new sanctions against Belarus
On 30 October, the Federal Council decided to adopt further sanctions against Belarus. This brings Switzerland in line with the measures adopted by the European Union on 29 June and reaffirms Switzerland’s close partnership with the EU with regard to sanctions. The changes will come into effect on 31 October. Link
OFSI amends humanitarian activities GL to include Lebanon
OFSI has amended General Licence INT/2023/3749168 to include Lebanon. The GL permits activities that provide humanitarian assistance and/or support basic human needs. Previously it only applied to such activities that related to the conflict in Isarael and the Occupied Palestinian Territories. The GL has also been amended to extend its application until 14 November 2025.
UK designates Iranian individuals and entities
The UK has designated 7 individuals and 2 entities under its Iran sanctions regime. The designated entities are:
- Farzanegan Propulsion Systems Design Bureau, a company operating in the Iranian defence sector; and
- the Iranian Space Agency, which has allegedly been involved in undermining Israel’s security.
The individuals designated are all either involved in the Iranian defence sector or in activities said to undermine Israel’s security and prosperity.
Ukraine: Switzerland implements further measures in 14th EU sanctions package
On 16 October, the Federal Council decided to adopt most of the measures in the EU’s 14th package of sanctions against Russia. The new measures will come into force on 17 October. On 8 July, 116 individuals and entities were already added to Switzerland's sanctions list, and on 21 August the first measures in the 14th sanctions package were adopted.
UK sanctions West Bank settler outposts
The UK has designated 7 entities under its human rights regime. The sanctions target 3 settler outposts and 4 organisations accused of supporting and inciting violence against Palestinian communities in the West Bank. Link
UK sanctions Russian oil tankers
The UK has designated 1 entity and specified 18 Russian oil tankers & 4 LNG tankers. The entity is Russian gas company Rusgazdobycha JSC, designated for its role in the Russian energy sector. The 22 specified vessels are barred from UK ports. This is the largest UK targeting of Russian oil tankers to date.
11 countries want UN to establish new DPRK sanctions monitoring team
In a joint statement, 11 countries say they intend to establish the Multilateral Sanctions Monitoring Team (MSMT) to monitor UN DPRK sanctions violations and evasion. The UN’s panel of experts that previously monitored the sanctions was disbanded in April 2024 after a veto by Russia. The 11 countries establishing the MSMT are Korea, Japan, the UK, USA, Australia, Canada, France, Germany, Italy, the Netherlands and New Zealand.