COMPLIANCE ETC: THINGS YOU MAY HAVE MISSED – MAY 19

After just watching an excellent short You Tube documentary about the 1972 expedition in which 2 Range Rovers became the first vehicles to cross the “green hell” of the Darién Gap, amzed to read today that, after 17 days in the Colombian Amazon jungle, 4 indigenous children missing after a plane crash have been found alive. I don’t think I’d last more than a day … By the way, the story of the expedition, part of a successful attempt to drive the whole length of the Pan-American Highway from Alaska to Cape Horn, is at –

https://www.youtube.com/watch?v=4hQKFxpu518

Incidentally, to give you an idea of how awful the Darién was, and is, the whole trip from Alaska to Argentina took 6 months – but it took 3 months to cross the Darién! Bear in mind, this is the same hellish place that migrants now cross, on foot, and in huge numbers…

As the Presidential primaries get under way, a court case has been launched seeking to stop use of the “RM” party symbol by the Realizando Metas party founded by former President Ricardo Martinelli. An alleged violation of IP rights is apparently alleged. It is also claimed that the the trademark “Achieving Goals and Design” formally belongs to someone else, having been registered in 2020.

19 MAY 2023

https://www.buymeacoffee.com/KoIvM842y

CANADA: NEW RUSSIA SANCTIONS LISTINGS

On 19 May, Canada announced that it was adding 17 individuals and 18 entities said to be linked to Russian companies that provide military technology and know- how to Russia’s armed forces, family members of listed persons.  It also designated 30 individuals and 8 entities allegedly involved in Russia’s ongoing human rights violations, including the transfer and custody of Ukrainian children in Russia.

https://www.international.gc.ca/world-monde/international_relations-relations_internationales/sanctions/russia-russie.aspx?lang=eng

FinCEN AND COMMERCE DEPARTMENT JOINT ALERT ON RUSSIA SANCTIONS CIRCUMVENTION

On 19 May, FinCEN and the US Commerce Department Bureau of Industry and security issued a joint Supplementary Alert urging continued vigilance for potential Russian export control evasion.  This builds on FinCEN and BIS’s first Joint Alert, issued in June 2022, and provides financial institutions additional information with respect to new BIS export control restrictions relating to Russia.

https://www.fincen.gov/sites/default/files/shared/FinCEN%20and%20BIS%20Joint%20Alert%20_FINAL_508C.pdf

US IMPOSES ADDITIONAL SANCTIONS AND EXPORT CONTROLS ON RUSSIAIN CORODINATION WITH PARTNERS

On 19 May, a news release from the US State Department was also concerned with the follow-up to the recent G7 meeting.  It includes an Annex listing a large number of Russian-registered airliner subject to restrictions.

https://www.state.gov/united-states-imposes-additional-sanctions-and-export-controls-on-russia/

US TARGETS RUSSIA’S CIRCUMVENTION AND EVASION, MILITARY-INDUSTRIAL SUPPLY CHAINS, AND FUTURE ENERGY REVENUES

On 19 May, a news release from the US Treasury detailed actions following the recent G7 meeting. 

https://home.treasury.gov/news/press-releases/jy1494

OFAC ADDS 22 INDIVIDUALS AND 104 ENTITIES TO RUSSIAN SANCTIONS LISTS

On 19 May, OFAC announced that a large number of individuals and entities had been added to its sanctions lists.  Of interest to me is the listing of an Isle of Man company, Hanley Limited, among the names from a variety of countries, not just Russia.

https://ofac.treasury.gov/recent-actions/20230519

OFAC CHANGES TO GENERAL LICENCES AND FAQ

OFAC: NEW RUSSIA SANCTIONS GENERAL LICENSES

On 19 May, OFAC announced –

General License 13E – Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024;

General License 66 – Authorizing the Wind Down of Transactions Involving Public Joint Stock Company Polyus;

General License 67 – Authorizing Certain Transactions Related to Debt or Equity of, or Derivative Contracts Involving, Public Joint Stock Company Polyus; and

General License 68 – Authorizing the Wind Down of Transactions Involving Certain Universities and Institutes.

https://ofac.treasury.gov/media/931786/download?inline

https://ofac.treasury.gov/media/931791/download?inline

https://ofac.treasury.gov/media/931796/download?inline

https://ofac.treasury.gov/media/931801/download?inline

OFAC IMPOSES AN ADDITIONAL REPORTING REQUIREMENT ON US PERSONS TO IDENTIFY ASSETS OF ENTITIES SUBJECT TO RUSSIA-RELATED SANCTIONS

On 19 May, OFAC advised that Directive 4 – Prohibitions related to transactions involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation – had been amended.  Amended FAQ 998 to 1002, 1004, 1005, and 1118 also refer.  US persons must submit a report on or before 18 June, and annually thereafter, on property in their possession or control with an interest, direct or indirect of an entity subject to Russia-related Directive 4, as amended (see FAQ 998).  Note that existing licenses or authorisations issued by OFAC pursuant to the prior version of Russia-related Directive 4 remain in effect.

https://ofac.treasury.gov/media/918806/download?inline

https://ofac.treasury.gov/faqs/search/998+999+1000+1001+1002

https://ofac.treasury.gov/faqs/search/1004+1005

https://ofac.treasury.gov/faqs/1118

OFAC: 2 NEW DETERMINATIONS OVER RUSSIA SANCTIONS

On 19 May, OFAC issued 2 new Determinations –

Architecture, Engineering, Construction, Manufacturing, and Transportation Sectors of the Russian Federation Economy; and

Prohibitions Related to Architecture Services and Engineering Services.

OFAC is also publishing 3 associated FAQ and removing FAQ 964, 1037, and 1085, which were incorporated into new FAQ 1126 to 1128.  OFAC has also amended FAQ 1059, 1061 and 1062.

https://ofac.treasury.gov/media/931771/download?inline

https://ofac.treasury.gov/media/931776/download?inline

https://ofac.treasury.gov/faqs/search/1126+1127+1128

https://ofac.treasury.gov/faqs/1059

https://ofac.treasury.gov/faqs/search/1061+1062

OFAC: AMENDED FAQ RE BLOCKING SANCTIONS ISSUED BY THE STATE DEPARTMENT ON POLIMETALL AO

On 19 May, OFAC reported that FAQ 1129 had been amended.  The FAQ says that the State Department designated Russia-based Polimetall AO on 19 May, and that the blocking sanctions apply only to this entity and any entities in which it owns, directly or indirectly, a 50% or greater interest.  

https://ofac.treasury.gov/faqs/1129

KAZAKHSTAN HAS BECOME A PATHWAY FOR THE SUPPLY OF RUSSIA’S WAR MACHINE.  HERE’S HOW IT WORKS

On 19 May, an article from OCCRP says that reporters traced several of these supply chains through Kazakhstan — and found that they run through companies newly established by Russians.

https://www.occrp.org/en/investigations/kazakhstan-has-become-a-pathway-for-the-supply-of-russias-war-machine-heres-how-it-works

RUSSIA SANCTIONS: 86 ENTRIES ADDED AND 3 DELETED BY UK AND ISLE OF MAN

On 19 May, the UK and the Isle of Man advised that 86 entries have been added to the consolidated list and are now subject to an asset freeze and trust services sanctions.  The new designations target individuals and organisations connected to Russia’s energy, metals, defence, transport, and financial sectors, including 9 organisations connected to Russia’s state-owned nuclear energy company.   

At the same time 3 existing entries had been deleted – Nikolay Yurievi PETRUNIN; Kyrylo Sergiyovich STREMOUSOV; and Vladimir Nikolayevich SUNGORKIN. 

A separate news release from the Isle of Man advised that the Russian sanctions guidance had been updated.

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1157892/Notice_Russia_190523.pdf

https://www.gov.im/news/2023/may/19/financial-sanctions-russia/

https://www.gov.im/news/2023/may/19/sanctions-guidance-russia/

https://www.rferl.org/a/russia-uk-sanctions-diamonds-shipping/32418864.html

https://www.gov.uk/government/news/uk-sanctions-target-russias-theft-of-ukrainian-grain-advanced-military-technology-and-remaining-revenue-sources