RegRally Insights: Sanctions Essentials

Welcome to our monthly newsletter on Sanctions, which is dedicated to everyone who wants to understand the latest trends and developments, get tips from our experts, and deepen their knowledge.

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US Treasury Sanctions Blockchain Entities for Evading Sanctions

The US Treasury Department's Office of Foreign Assets Control (OFAC) sanctioned 13 entities and two individuals, including BitPapa and NetExchange, on March 25, 2024, for their involvement in developing and operating blockchain-based services to evade sanctions. OFAC stated that these entities facilitated transactions or provided services enabling OFAC-designated entities to evade sanctions, particularly amid Russia's efforts to bypass US sanctions and support its actions in Ukraine. Bitpapa and NetExchange were specifically sanctioned for their roles in transacting with OFAC-sanctioned entities, including Hydra market and various Russian banks, demonstrating the increasing scrutiny of cryptocurrency exchanges in sanction enforcement efforts. Read more

European Commission Updates Sanctions FAQs on Russia

The European Commission has revised 19 FAQs on sanctions against Russia, maintaining restrictions on providing certain services to Russian governments and entities. Key points include prohibitions on EU subsidiaries providing restricted services to Russian parent companies and non-Russian branches of Russian entities. Additionally, the ban extends to the indirect supply of prohibited services via EU subsidiaries in third countries. While exemptions exist for services to Russian entities owned by EU entities until June 20, 2024, authorisation will be required to continue providing restricted services, with specific guidelines for IT consulting services outlined. Read more

EU Prepares 14th Package of Sanctions Targeting Russia

The European Union is finalising a 14th package of sanctions against Russia, focusing on circumventing restrictive measures, especially in the maritime sector. Valdis Dombrovskis, the European Commission's Executive Vice-President, emphasised the potential effectiveness of these sanctions despite their impact on the Russian economy. He highlighted Russia's rapid establishment of new trade routes to countries not under sanctions. Recent sanctions before the anniversary of Russia's invasion of Ukraine target individuals and entities undermining Ukraine's integrity, particularly in military sectors, as well as those involved in missile supply from North Korea to Russia and the mistreatment of Ukrainian children. Read more

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EU Approves Criminal Sanctions for Violating EU Sanctions

The EU Council has granted final approval for implementing criminal sanctions for EU sanctions violations across member states. This decision criminalises actions such as evading travel bans or trading in sanctioned goods, with penalties including fines and imprisonment for intentional violations. Member states are mandated to enforce effective and proportionate criminal penalties for sanctions breaches, with intentional violations carrying the possibility of imprisonment as the maximum penalty. Legal persons, including companies, can be held accountable for offences committed by individuals in leading positions within the organisation, potentially facing sanctions such as business activity disqualification and permit withdrawal. The directive will come into effect 20 days after publication in the Official Journal of the EU, with member states given 12 months to incorporate its provisions into national legislation. Read more

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EU Implements New Reporting Requirements for Entities Linked to Russia

The EU has introduced Article 5r of Regulation 833/2014, mandating reporting for entities with strong ties to Russia. Effective May 1, 2024, EU entities with over 40% ownership by Russian entities must report quarterly transfers exceeding EUR 100,000. Financial institutions will report such transfers semi-annually starting July 1, 2024. Reports in Lithuania go to the Financial Crimes Investigation Service, following the European Commission's format. Read more

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EU Extends Sanctions on Iranian Regime Over Human Rights Concerns

The Council of the European Union has prolonged sanctions on the Iranian regime until April 2025, targeting seventeen new individuals, including high-ranking security force officials and members of the Islamic Revolutionary Guard Corps, with measures like asset freezes and travel bans. These sanctions address allegations of senior officials suppressing protests and violating human rights. Read more

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EU Updates Sanctions on Ukraine Threats

The Council's Decision (CFSP) 2024/8471, adopted on March 12, 2024, introduces updated listings for 97 individuals and nine entities while removing nine deceased persons and three others from the list, aiming to counter actions threatening Ukraine's territorial integrity. Candidate countries and EFTA members have aligned their national policies with this decision. Read more

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EU Imposes Sanctions for Human Rights Abuses in Palestinian Territories

The Council's decision on April 19, 2024, added four individuals and two entities to the EU Global Human Rights Sanctions Regime for their involvement in serious human rights abuses against Palestinians in the West Bank, including torture and property violations. This brings the total number of sanctioned individuals and entities to 108 and 28, respectively, under the regime. Read more

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EU Adds Three Entities to Human Rights Sanctions List Over Alleged Involvement in Israel Terror Attacks

The Council of the EU has expanded its human rights sanctions list, targeting the Al-Quds Brigades, Palestinian Islamic Jihad, and Hamas Nukhba Force for their suspected roles in terrorist attacks in Israel in October 2023. This decision brings the total number of sanctioned individuals and entities to 104 and 26, respectively, with measures including asset freezes and travel bans. Read more

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Lithuania Extends Sanctions on Russian and Belarusian Citizens, With Limited Additional Measures

Lithuania has prolonged its national sanctions on individuals from Russia and Belarus for another year, maintaining restrictions on visa issuance, e-residency, entry, real estate acquisition, and residence permits. Despite proposals for stricter measures, such as limiting visits and revoking permits for expressing support for Putin, the updated law largely retains existing restrictions. Read more

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