RegRally Insights: Sanctions Essentials

ECOVIS ProventusLaw welcomes 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.

EU Updates Guidance on Sanctions Enforcement

The Council of the European Union has released updated Best Practices for implementing restrictive measures, clarifying key concepts in EU sanctions. The guidance, published on July 3, 2024, refines the ownership threshold for EU asset freezes, stating that entities are considered owned if a designated person holds 50% or more of proprietary rights or a majority interest. It also provides new examples of control, including the use of front persons or trusts. The update emphasizes that “acting on behalf or at the direction” of an entity is as significant as ownership or control.

US, UK, and EU Impose Coordinated Sanctions on Iran and Russia

In September 2024, the US, UK, and EU introduced joint sanctions against Iran and Russia in response to Iran supplying ballistic missiles to Russia for use in Ukraine. The sanctions include travel bans and asset freezes targeting Iranian individuals and organizations involved in missile and drone deliveries and measures against Iran Air and Russia’s shipping sector. These actions demonstrate Western nations’ commitment to holding both Iran and Russia accountable for their military involvement in the Ukraine conflict.

US, UK, and EU Announce Sanctions on Iran and Russia Over Missile Supplies

In September 2024, the US, UK, and EU imposed coordinated sanctions on Iran and Russia following Iran’s provision of ballistic missiles to Russia for its war in Ukraine. The sanctions include travel bans and asset freezes on Iranian individuals and organisations involved in supplying missiles and drones, along with sanctions on Iran Air and entities in Russia’s shipping sector. These actions reflect ongoing efforts by Western nations to hold Iran and Russia accountable for their military contributions to the Ukraine conflict.

Lithuania and Regional Partners Condemn IMF’s Plans to Resume Cooperation with Russia

In response to the International Monetary Fund’s (IMF) decision to resume economic consultations with Russia, finance ministers from Lithuania, Latvia, Estonia, Finland, Denmark, Sweden, Norway, Iceland, and Poland it strongly condemned the move. The ministers expressed concerns that this step could signal the normalization of relations with Russia despite its ongoing aggression in Ukraine. Lithuanian Finance Minister Gintarė Skaistė warned that the IMF’s cooperation risks damaging its reputation and could be used by Russia for propaganda. The ministers urged the IMF to reconsider its decision and maintain a firm stance against Russia.

European Commission Updates EU Dual-Use List for Export Controls

The European Commission has published a Delegated Regulation updating the EU Dual Use List, which regulates the export of dual-use items. The list, aligned with multilateral export control regimes, is updated annually and includes revisions to technical definitions, control parameters, and descriptions across several categories. Changes reflect technological advances and include updates to nuclear materials, special materials, electronics, telecommunications, and aerospace items. The new regulation will take effect following its publication in the EU’s Official Journal, which is expected later this year.

G7 Releases Joint Guidance to Prevent Evasion of Sanctions and Export Controls on Russia

The G7 nations and the European Union have published joint guidance for the first time to help industries prevent evasion of sanctions and export controls imposed on Russia. The guidance highlights priority areas, such as high-risk items and red flag indicators of evasion (suspicious import/export behaviour, misleading documentation, abnormal payment routing, and customer information). It provides best practices for enhanced due diligence. Companies are advised to analyse risks, cross-reference sanctions lists, and report suspicious transactions to authorities to ensure compliance.

Switzerland Updates Sanctions List Related to the Ukraine Crisis

On 24 September 2024, Switzerland amended its sanctions list regarding Ukraine. The update includes changes to the entries for several individuals, such as Alexander Dmitrievich Pumpyansky, Andrey Igorevich Melnichenko, Dmitry Alexandrovich Pumpyansky, Dmitry Vladimirovich Konov, Alexey Viktorovich Kuzmichev, and Oleg Vladimirovich Deripaska. Additionally, eight entries were removed from the list. Full details of the sanctions are available on the Switzerland section of the relevant site.

German Authorities Shut Down 47 Crypto Exchange Platforms Used for Money Laundering

The Frankfurt Public Prosecutor’s Office and the Federal Criminal Police Office (BKA) have dismantled 47 exchange platforms in Germany that were used for illicit activities. These services allowed users to exchange conventional currencies and cryptocurrencies without adhering to anti-money laundering regulations, including identity verification. The platforms facilitated anonymous transactions, making them a key part of the cybercrime ecosystem, used by ransomware groups, darknet traders, and botnet operators to launder proceeds of crime. The shutdown is a major step in combating financial anonymity in cybercrime.