ECOVIS ProventusLaw welcomes you to its 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.
EBA Issues Guidelines on Sanctions Compliance for Financial Institutions and Crypto-Service Providers
The European Banking Authority (EBA) has published EBA/GL/2024/15, which sets out EU standards for financial institutions (FIs) and crypto asset service providers (CASPs) on sanctions compliance governance, policies and screening systems.
Key Requirements:
- Risk Assessment Alignment: FIs and CASPs must assess the effectiveness of screening systems through their restrictive measures risk assessments.
- Streamlined Questionnaires: Use pre-filled cognitive questionnaires for easier customer updates.
- Adaptation to Characteristics: Policies, procedures, and controls must be customized based on an institution’s size, complexity, and exposure to sanctions.
- Resource Assessment: Institutions should evaluate their access to necessary resources for screening system use.
- Annual Review: A yearly review of the screening system is mandatory, with additional reviews if concerns arise.
- System Understanding: Institutions should fully document the capabilities and limitations of their screening systems.
- Demonstration of Adequacy: Institutions must show competent authorities that their screening systems are adequate for compliance.
UK Imposes Major Sanctions on Russia’s Military and Mercenary Networks
The UK has targeted 56 entities, individuals, and vessels in its largest sanctions package since May 2023. The measures focus on:
- Disrupting Military Supply Chains: Blocking critical materials from China, Turkey, and Central Asia to Russia.
- Sanctioning Mercenary Groups: Targeting groups like the Africa Corps for human rights abuses in Africa.
- Individuals and Proxies: Sanctioning 11 individuals destabilizing Sub-Saharan Africa.
- GRU Link: Sanctioning a GRU agent involved in the 2018 Salisbury Novichok attack.
OFAC Expands Sanctions Against Russia’s Financial Sector
In response to Russia’s ongoing war in Ukraine, the U.S. Department of the Treasury’s OFAC has announced comprehensive measures to disrupt Russia’s financial access. Key actions include:
1. Sanctions on Gazprombank: Gazprombank and six foreign subsidiaries are sanctioned, blocking entities it owns 50% or more.
2. Expanded Financial Sanctions: Over 50 Russian banks are targeted to isolate Russia and limit its access to military technology.
3. Sanctions on Securities Registrars: 40+ Russian registrars designated for attempting to bypass sanctions.
4. SPFS Alert: Financial institutions participating in Russia’s alternative to SWIFT face significant sanctions risks.
5. Designations of Russian Officials: 11 central bank staff and Russian nationals in foreign banks are sanctioned.
6. General Licenses: U.S. persons are allowed wind-down periods and exceptions for diplomatic and humanitarian activities.
US Sanctions Over 300 Entities and Individuals Linked to Russia’s War Effort
The U.S. Departments of Treasury and State have designated more than 300 individuals and entities in connection with Russia’s military actions in Ukraine. These sanctions, implemented under Executive Order 14024, target those who provide support to, act on behalf of, or engage in sanctioned sectors of the Russian economy. The measures focus on non-Russian actors, particularly from China, Turkey, and other countries in Asia and Europe, who play a key role in evading sanctions and supporting Russia’s military-industrial complex. This collective approach aims to further isolate Russia economically and disrupt its war effort.
OFAC Issues Updated Sanctions Compliance Guidance for Maritime Transport Industry
The U.S. Office of Foreign Assets Control (OFAC) has issued updated sanctions compliance guidance for the maritime sector that provides recommendations to help industry participants – such as brokers, insurers, and port authorities – mitigate the risks associated with sanctions evasion. The guidance focuses on detecting deceptive shipping practices, identifying sanctioned parties in transaction documents, addressing risks in vessel registration, and encouraging the inclusion of sanctions clauses in contracts. While not legally binding, it is intended to support the development of proactive compliance frameworks to combat evasion tactics in the maritime industry.
OFAC Sanctions Al-Qatirji Company and Affiliates for Terrorism-Related Activities
The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) has sanctioned 26 individuals, entities, and vessels associated with the Al-Qatirji Company, a Syrian conglomerate involved in facilitating oil sales between the Syrian regime and ISIS. Initially sanctioned in 2018 under Executive Order 13582, Al-Qatirji has now been redesignated under Executive Order 13224 for terrorism-related activities. The sanctions highlight the company’s role in facilitating oil transactions from Iran’s IRGC-Qods Force to Syria and China, though no Chinese buyers of the oil have been sanctioned despite evidence linking them to these transactions.
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