Still on travels, so blog may still be a bit patchy and hit and miss…

24 June 2019


On 24 June, OFAC announced that it had designated  senior IRGC commanders said to be behind Iran’s “destructive and destabilising activities”.  These are 8 senior commanders of Navy, Aerospace, and Ground Forces of the Islamic Revolutionary Guards Corps (IRGC), who are said to sit atop a bureaucracy that supervises the IRGC’s regional activities.  Also designated is the country’s Supreme Leader. A new Executive Order  imposes asset freezes and blocking measures on Iran’s Supreme Leader Ali Khamenei and his office, anyone appointed by him or his office as state officials.  The US has said Iran’s Foreign Minister Zarif will be sanctioned shortly.

Privy Council confirms automatic right to appeal disclosure provisions within freezing orders

On 17 June, Harneys published a briefing about a BVI case before the UK Privy Council (the highest court of appeal for the BVI, as well as the Crown Dependencies and other British Commonwealth territories).  The Court held that leave is not required to appeal disclosure provisions within a freezing injunction.

Lloyds Bank Freezes Thousands of Jersey Accounts in Compliance Crackdown

KYC 360 on 24 June reported that the Lloyds Banking Group has frozen the Jersey-based accounts of approximately 8,000 offshore clients after they failed to submit identifying documents for 3 years.  The article says that the UK-based bank began to bolster its AML compliance controls at its Jersey-based international banking arm at the end of 2018.

US and Canada sanction Nicaraguan officials over human rights       

KYC 360 reported on 24 June that the US had designated 4 officials,  tying them to a tough crackdown on street demonstrations that began in Nicaragua country in April 2018.  Canada didn’t immediately identify who its sanctions were aimed at, saying only that they are “key members” of Nicaragua’s government.

Directors’ company obligations trump family interests 

In an article from Herbert Smith Freehills on 21 June, the firm considers a recent High Court case and says that directors must be loyal to and to act in the best interests of the company of which they are directors.  Whilst directors in a majority family owned business may “owe” moral duties to their family members which may conflict with their duties owed to the company, they must prioritise the interests of the company.  It says that the case discussed is a timely reminder of these rules. The firm says that the key takeaway of the case is that whenever a family business concerns a corporation, it is subject to the regime of corporate law and directors are bound by stringent directors’ duties, including fiduciary duties and statutory duties under the Companies Act 2006.

Combating corruption in Latin America – the Capacity to Combat Corruption (CCC) Index

On 24 June, Control Risks reported that corruption has been a critical hurdle for Latin American countries for a long time, denting growth, weakening democracy and governance, and undermining the human rights of millions of citizens. Now the Americas Society/Council of the Americas (AS/COA) and Control Risks have announced the launch of the Capacity to Combat Corruption (CCC) Index, a new tool assessing Latin American countries’ ability to uncover, punish and deter corruption.  The report and Index is available at –

Switzerland Says $133 Million Belonging To Gulnara Karimova To Be Sent To Uzbekistan 

On 24 June, Rferl reported that Switzerland said it would send $133 million in seized assets linked to Gulnara Karimova to Uzbekistan, amid a continuing international struggle over the fate of more than a billion dollars tied to the elder daughter of the late president of Uzbekistan.

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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