The Office of Foreign Assets Control has updated its Frequently Asked Questions to give additional guidance regarding the transport of Russian crude oil prior to the implementation of the oil price cap. FAQ 1094, issued Oct. 31, explains that Russian-origin crude oil loaded onto a vessel for maritime transport prior to Dec. 5 will not be subject to the price cap (also known as the “maritime services policy”) provided that the oil is unloaded at the port of destination prior to 12:01 a.m. EST, Jan. 19, 2023.
The EU General Court in an Oct. 26 judgment annulled the sanctions listing of Dmitry Ovsyannikov under the Russia sanctions regime. The European Council said that given his former positions in the Russian government since 2017, Ovsyannikov undermined Ukraine's sovereignty. The General Court said the council could not justify this finding because Ovsyannikov resigned as Sevastopol governor in 2019 and stopped working as a deputy minister in 2020. The EU had to show that his links with the government since these dates justified his designation -- something the bloc failed to do, the court held. However, Ovsyannikov is still sanctioned following a European Council decision in September that was taken up after the hearing in this case.
The U.K.'s Office of Financial Sanctions Implementation imposed two general licenses under its Russia sanctions regime. The Securing Energy for Europe license lets an individual or entity grant a category five loan or enter into an arrangement to grant this loan to Gazprom Germania or any of its subsidiaries. These loans can be issued for over-the-counter gas trading, payments of credit arrangements and invoices by Gazprom or any of its subsidiaries, customer credit arrangements, the provision of clearing services to Gazprom or any of its subsidiaries, payment between Gazprom or any of its subsidiaries, or the provision of financing for letters of credit. The license will run 11:59 p.m. Oct. 28 to 11:59 p.m. Oct. 29, 2023. The Loans and Securities amendment, which runs 11:59 p.m. Oct. 28 to 11:59 p.m. Nov. 5, permits an individual or entity to directly or indirectly enter into an arrangement to grant a category five loan, though it does not permit activity that would otherwise be permitted under the Securing Energy for Europe license.
A group of European countries not in the EU aligned themselves with recent EU sanctions moves under the restrictions regimes pertaining to Ukraine and those threatening the sovereignty of Ukraine, the European Council announced Oct. 26. On Oct. 20, the council added three Iranian individuals and one entity to the Ukraine sanctions regime for supplying the Russian army with Unmanned Aerial Vehicles. The countries of North Macedonia, Montenegro, Albania, Ukraine, Bosnia and Herzegovina, Iceland, Liechtenstein and Norway also implemented the decision, the council said.
DOJ's recent moves charging 11 individuals and various corporate entities for their roles in schemes to evade U.S. sanctions and export controls on Russia signal the government's continuing efforts to "aggressively enforce" restrictions on Russia, law firm Paul Weiss said in an analysis posted online Oct. 26. As a result, multilateral corporations with international supply chains need to ramp up compliance measures and be aware that international cooperation has expanded the reach of U.S. sanctions enforcement, the firm said.
The U.K.'s overseas territories have frozen Russian assets worth over an estimated $9 billion, including $8.4 billion by the Cayman Islands and over $400 million by the British Virgin Islands, the British government said Oct. 26. Releasing its response to the House of Commons Foreign Affairs Committee June 2022 report, "The cost of complacency: illicit finance and the war in Ukraine," the government also said crown dependencies have frozen assets worth over $1.15 billion, including nearly $2.2 million by the Isle of Man and nearly $5.8 million by Guernsey.
The Paris Court of Appeals ordered the French government to release an impounded yacht owned by EU-sanctioned Russian billionaire Alexey Kuzmichev due to procedural errors made during the vessel's seizure, according to an unofficial translation. Kuzmichev is one of the main shareholders of Russia's Alfa Bank. French customs seized the yacht, called La Petite Ourse, in March following Kuzmichev's addition to the sanctions list. The yacht was moored in Antibes. The French court said the customs agents did not follow correct procedure when searching the vessel, incorrectly relying on an authority that permitted a search in connection with suspected fraud.
The EU released updated guidance on the provision of business services under its Russia sanctions regime, adding an overview table of the EU restrictions on services. The European Commission added five questions to its FAQs about business services, covering how the sectoral scope for IT consultancy services is defined, whether the measures on IT consultancy services hamper the conditions of civil society organization in Russia, which software updates are exempted from the ban on IT consultancy services, what activities are covered on the architectural and engineering services ban and what activities are covered by the ban on legal advisory services.
The Office of Foreign Assets Control sanctioned nine people and 12 entities this week in an effort to counter "persistent malign influence campaigns and systemic corruption in Moldova" by Russian actors, the agency said.
The U.K. added three Iranian individuals and one Iranian entity to its Russia sanctions regime pertaining to their involvement in sending unmanned aerial vehicles (UAVs) to the Russian military for use in Ukraine, the Office of Financial Sanctions Implementation said Oct. 20. The individuals, Saeed Aghajani, head of the Iran Revolutionary Guard Corps Aerospace Force UAV command; Mohammad Bagheri, chairman of the Armed Forces General Staff; and Seyed Hojjatollah Qureishi, head of the Iranian Defense Ministry's Supply and Logistics Division, are subject to an asset freeze and travel ban. OFSI also sanctioned Shahed Aviation Industries, an Iranian UAV manufacturer. The OFSI notice amended the entry for Oleksandr Saulenko, a senior official installed in the Russian administration of Berdyansk in the temporarily controlled area of Zaporizhzhia, regarding date of birth. The U.K.'s move follows the EU's listing of the same individuals and entity (see 2210200014).