SanctionsAlert.comSummer Sanctions Round Up
September 5, 2018

U.S. Cracks Down on Russia with Global Magnitsky Regulations and New Sanctions

As of June 29,2018, the Global Magnitsky Sanctions Regulations (31 CFR part 583) took effect on the Federal Register. These regulations implement the Global Magnitsky Human Rights Accountability Act (or U.S. Global Magnitsky Act) as well as Executive Order 13818 of December 20, 2017.

The U.S. Global Magnitsky Act allows the U.S. government to address human rights on a global scale by designating certain individuals based on their perceived human rights abuses and corruption. As a result of designation, all of the property and interests in property within U.S. jurisdiction of the designated individuals and entities are blocked, and U.S. persons are generally prohibited from engaging in transactions with them.

Currently, the large majority of designations are comprised of high-up government officials within the Russian government.

On August 8, the U.S. imposed further sanctions on Russia by banning over 100 Russian diplomats. This action came after it was determined that Moscow had used a nerve agent against a former Russian agent and his daughter on UK soil. Sergei Skripal and his daughter, Yulia, were found unconscious on a bench in the southern English city of Salisbury in March after a liquid form of the Novichok type of nerve agent was applied to their home’s front door.

Would you like to stay up to date with the latest in the battle against corruption? Join us at the SanctionsAlert.com Sanctions Risk Management Conference, where you can listen in during the panel – Stirring the PEP’s Nest: Applying Global Magnitsky Sanctions to Prevent Abuse and Corruption

U.K. Withdrawal Act To Incorporate E.U. Blocking Statute after ‘Brexit’

On 26 June 2018, the U.K. passed the European Union (Withdrawal) Act 2018, which provides for the U.K.’s withdrawal from the E.U. after ‘Brexit’ on March 29, 2019. The Withdrawal Act formally incorporates most E.U. laws into U.K. law. Notably, under Section 3 of the Withdrawal Act, E.U. regulations operative immediately before Brexit – such as the E.U. Blocking Regulation – will be incorporated into domestic U.K. law.

Following President Trump’s announcement that the U.S. would be withdrawing from the Iran nuclear deal on May 8th, E.U. leaders made the decision to activate the so-called Blocking Regulation (formerly Regulation 2271/96), which bans European companies, under threat of punishment, from complying with U.S. sanctions against Iran. The E.U. Blocking Statute, however, has never actually been used in practice and could be seen as more of a political move than a legal enforcement tool. The Statue will require the agreement of all 28 EU member states to implement, which could be a lengthy process.

Would you like further updates on the U.K. and the potential impact of ‘Brexit’ on sanctions law? Join us on September 13th, 2018 at 10am ET for a webinar on:The Potential Affects of Brexit on U.K. Sanctions Law and How Compliance Officers Can Prepare for the Switch.

OFAC and Ericsson Agree $145k Settlement for Violation of Sudanese Sanctions

On June 6th, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced an agreed settlement of $145,893 with Ericsson, Inc. of Plano, Texas and Ericsson, AB of Stockholm, Sweden. Ericsson US and Ericsson AB agreed to settle their potential civil liability for an apparent violation of the Sudanese Sanctions Regulations.

According to the notice, employees of both Ericsson branches conspired to export and re-export a satellite hub to/from the U.S. and Sudan. OFAC determined that EUS and EAB voluntarily self-disclosed the apparent violation, and that the apparent violation constituted an egregious case. Payment was required within 15 days of the agreement.

Would you like to learn more about how to stay compliant with OFAC sanctions? Sign up for the SanctionsAlert.com Sanctions Risk Management Conference, where you can listen in at our round table – Managing Third Party Sanctions Risks, led by Richard Tornberg of Ericsson AB.

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