RegRally Insights: Sanctions Essentials – November 2024

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EU Issues New Guidance to Prevent Russian Sanctions and Export Control Evasion

The European Commission has released updated guidance to help industries identify and prevent Russian tactics to circumvent export controls and sanctions. This guidance supports businesses in protecting G7 technologies from unauthorised use, managing reputational and liability risks, and reinforcing current regulatory measures. Introduced alongside the G7’s Enforcement Coordination Mechanism (ECM), which includes a dedicated Sub-Working Group for Export Control Enforcement, the guidance provides industries with a list of high-risk items, updated indicators of sanctions evasion, best practices for risk management, and resources to strengthen due diligence processes.

FCIS Issues Updated Guidelines for Lithuanian Entities on International Sanctions Compliance

The Financial Crimes Investigation Service (FCIS) has released updated guidelines clarifying Lithuanian entities’ obligations for international sanctions compliance under the UNSCR 1373 framework. Obliged entities must perform Financial Sanctions Checks against EU sanctions lists, UN Security Council targeted sanctions, and the FCIS-managed UNSCR 1373 list. All identified assets of persons or entities on the UNSCR 1373 list must be frozen immediately. Entities are required to report frozen funds or assets to FCIS within two working days.

U.S. Expands Sanctions on Iran’s Petroleum Sector Following Attacks on Israel

In response to recent attacks on Israel, the United States is tightening sanctions on Iran’s petroleum and petrochemical sectors to curb revenue streams that fund Iran’s nuclear and missile programs and support for terrorism. Under the SHIP Act, this includes identifying critical industry sectors and sanctioning entities and vessels involved in transporting Iranian oil. The U.S. Treasury and State Departments are enforcing these measures to disrupt Iran’s illicit oil network and reinforce compliance with existing U.S. sanctions.

Switzerland Adopts EU’s 14th Sanctions Package Against Russia with Sweeping New Measures

Switzerland has implemented the EU’s 14th sanctions package, marking its strictest sanctions against Russia. The measures add 116 individuals and entities to the sanctions list and broaden trade restrictions, covering liquefied natural gas (LNG), cultural items, and Switzerland’s ghost fleet linked to Russia. New prohibitions now affect transactions involving Russian claimants in arbitration (Annex 15a), cryptocurrency service providers (Annex 15b), and financial institutions using alternatives to SWIFT, such as Russia’s System for Transfer of Financial Messages (Annex 14a). Although the annexes are empty, these bans are expected to take effect soon, requiring Swiss entities to prepare for compliance adjustments.

FATF Introduces Regional Bodies’ Guest Initiative, Welcoming Cayman Islands and Senegal

The Financial Action Task Force (FATF) has appointed the Cayman Islands and Senegal as the inaugural guest members under its new Regional Bodies’ Guest Initiative. This program facilitates closer participation of selected jurisdictions in FATF activities, aiming to strengthen their alignment with global anti-money laundering and counter-financing of terrorism (AML/CFT) standards. The initiative also offers these guest members a valuable platform for knowledge exchange and capacity building in AML/CFT efforts.

UK Expands Sanctions Against Russian-Linked Individuals and Entities Over Ukraine Destabilization Efforts

The UK’s Foreign, Commonwealth, and Development Office (FCDO) has imposed additional sanctions under the Russia (Sanctions) (EU Exit) Regulations 2019. This latest expansion includes asset freezes and restrictions on trust services aimed at six designated persons and entities involved in destabilising Ukraine and supporting Russia’s digital and IT sectors. Those targeted include Ilya Gambashidze, Andrey Perla, Nikolai Tupikin, ANO Dialog, Social Design Agency, and Structura National Technologies. The sanctions highlight the UK’s commitment to countering support for Russia’s aggressive actions in Ukraine.

Lithuania’s AML Center Holds Training on Sectoral Sanctions Compliance

Lithuania’s AML Center recently conducted a detailed training session on sectoral sanctions compliance, highlighting the complexities of sanctions affecting Russian and Belarusian markets. The session covered Lithuania’s approach to these sanctions, compliance best practices, and key red flags for spotting potential sanctions evasion. Attendees learned about the regulatory landscape, compliance essentials, and risk management tools. Through case studies and interactive discussions, AML Center speakers emphasised proactive strategies to help financial institutions navigate Lithuania’s rigorous sanctions framework effectively.

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