The European Commission released a general guidance document on implementing due diligence practices to halt the circumvention of the sanctions on Russia. The guidance includes risk assessment of possible sanctions circumvention, due diligence best practices, circumvention red flags related to business partners and buyers, and EU sanctions whistleblower tools. The due diligence best practices section addresses the stakeholder and transaction levels and the level of the goods themselves.
The EU General Court this week upheld one application for delisting under the Russia sanctions regime and rejected six others. The court removed former Ozon CEO Aleksandr Shulgin from the sanctions list, saying his relisting was not justified. The court said that given Shulgin had resigned his post and the European Council had not looked in why listing was still proper, he was not properly sanctioned, according to an unofficial translation.
The EU added six individuals to its Global Sanctions Regime for their role in perpetuating "serious human rights violations" in Russia and Ukraine, the European Council announced. The individuals include prosecutors and judges in Russia-occupied Crimea who participated in the "politically motivated court proceedings" against journalist Vladyslav Yesypenko. The council also sanctioned two members of the Russian Federal Security Service who either tortured Yesypenko or investigated him.
Treasury Secretary Janet Yellen said despite the fact that Russia has managed to use ships and insurance companies from countries that didn't agree to a price cap on Russian oil sales, the sanction is working.
The U.K.'s Financial Conduct Authority released a review of the country's sanctions systems on Sept. 6, finding firms that carried out risk exposure assessment ahead of Russia's invasion used proper practices. The review also found many firms needing better governance and oversight, and said certain companies were "too reliant on third-party" sanctions compliance tools and didn't align their practices with U.K. sanctions rules. The review spotted various backlogs regarding sanctions screening alerts and said some firms didn't have "adequate internal expertise," the report said.
The U.K. added 11 Russians to its sanctions regime related to cyberattacks against the country. In a Sept. 7 notice, the Office of Financial Sanctions Implementation imposed restrictions against the individuals for contributing to ransomware attacks that threaten the U.K. and "cause economic loss to, or prejudice the commercial interests of, those companies affected by the activity."
The Bureau of Industry and Security issued a temporary denial order last week against three people and four companies for their involvement in a scheme to illegally procure more than $225,000 worth of U.S. electronics components for Russia’s military. One of the individuals, Russian-German national Arthur Petrov, was arrested Aug. 26 in Cyprus and charged by DOJ with violating export controls and smuggling controlled goods from the U.S.
The Office of Foreign Assets Control this week sanctioned two people and one entity involved in helping North Korea’s weapons and missiles program earn revenue. The designations target Jon Jin Yong and Sergey Mikhaylovich Kozlov, who coordinated work for North Korean construction workers in Russia and procured items used in the ship-building industry. OFAC also sanctioned Intellekt, a company that Yong used in a Moscow-based construction project, for being owned or controlled by Kozlov.
Financial technology company Wise Payments Limited violated the U.K.'s sanctions on Russia when it allowed a company owned by a sanctioned person to withdraw funds from a business account, the U.K. said this week. The announcement marked the U.K.’s first use of its new sanctions enforcement disclosure “power,” an authority it acquired last year that allows it to publish details of sanctions violations in cases where the party isn’t hit with a monetary penalty.
Ukraine's National Agency on Corruption Prevention released a database that tracks the circulation of art objects bought or sold by sanctioned Russian individuals, the agency announced. The database has information on over 300 pieces of art estimated at $2 billion and allows users to report information pertaining to the art pieces.