Russia extends Turkey sanctions

 

Russia imposed sanctions on Turkey, in the form of a decree “on measures to ensure Russia’s national security and protect nationals of the Russian Federation from criminal and other illegal actions and to use special economic measures against the Turkish Republic.” By that decree, Russia banned or restricted imports of certain Turkish goods, including fruit and vegetables, suspended its visa-free travel agreement with Turkey and banned charter flights between Russia and Turkey.

President Putin today signed an order extending those sanctions, by bringing into force some of the sanctions imposed on November 28 that had not yet been implemented. The new order also bans a number of Turkish organisations or limits their activities in Russia.

EU delists prominent Syrian businessman 

Last week, the EU de-listed Samir Hamsho and his companies Al Buroj Trading and Syria Steel/Hmisho Steel from its sanctions measures on Syria. Samir Hamsho was listed for being a prominent Syrian businessman benefitting from and supporting the Syrian regime, for having been appointed to the Homs Chamber of Commerce by the Minister of Industry in 2014, and for owning the designated companies named above.

EU Parliament resolution calls for Maldives sanctions

The European Parliament has passed a resolution calling for the EU to impose asset freezes and travel bans on members of the Maldivian government and their leading supporters in the Maldivian business community.  The resolution expresses “deep concern about the gradual deterioration of the democratic standards and increasingly authoritarian tendencies in the Maldives”, and calls for “the Maldives government to release, immediately and unconditionally, former President Mohamed Nasheed, former Vice-President Ahmed Adeeb, and former defence ministers Tholhath Ibrahim and Mohamed Nazim, together with Sheikh Imran Abdulla and other political prisoners”.

The European Parliament adopted a resolution calling for the release of former President Nasheed in April, and in October the UN Working Group on Arbitrary Detention ruled that Nasheed’s detention was unlawful and called for his immediate release. The Maldivian parliament has passed legislation making it a treasonable offence to call for the imposition of sanctions and associated penalties against the Government of the Maldives and its members.

US adds targets to its Russia sanctions

The US has sanctioned 34 new people and entities under its Ukraine-related Russia sanctions regimes. Of the 34, 14 are said to be linked to those that have engaged in serious and sustained evasion of sanctions or are owned by a designated entity, 6 are alleged separatists who have threatened the security or stability of Ukraine, 2 are former Ukrainian government officials said to have been complicit in the misappropriation of public assets or to have threatened the security of stability of Ukraine, and 12 are entities that operate in the contested Crimea region of Ukraine. The US also identified a number of subsidiaries that are owned by listed entities VTB Bank, Sberbank, and Rostec.

 In the US Treasury’s press release Acting Director of OFAC John Smith stated that “It is critical that Russia takes the steps necessary to comply with its obligations under the Minsk Agreements and to ensure a peaceful settlement of the conflict in Ukraine”, adding that the US is “closely matching its designations with those of our international partners”. The press release notes the US’ “sustained commitment to a policy of non-recognition with respect to Russia’s purported annexation of Crimea, and our intent to maintain Crimea-related sanctions until Russia ends its occupation of the peninsula”. This reflects the position taken by the EU; several of the people and entities newly designated by the US have previously been listed by the EU. The EU renewed its own sectoral sanctions on Russia on Tuesday.

HM Treasury has published a note providing guidance to NGOs on operating within sanctions legislation. The guidance states that:

1. 1. The purpose of terrorist asset freezing regimes is to prevent funds from being used or diverted for terrorist purposes. The purpose of other international sanctions regimes is “to influence the behaviour of the targets of the sanctions by increasing the cost of doing business, denying them access to resources needed for the unwelcome behaviour, and to send a broader political message condemning the target’s behaviour. In Syria, the aims of sanctions are to downgrade Assad’s ability to wage war on his people and pressure the regime into reassessing its position and reengaging in negotiations with the moderate opposition”.
2. The purpose of the licenses from HM Treasury are to “mitigate the impact of an asset freeze on certain aspects of a designated person’s life, whilst still ensuring that funds cannot be diverted for terrorist purposes or to support activities such as human rights violations and nuclear proliferation”. HMT say that it would be “unusual” for licences to be granted to cover payments made overseas; they “usually cover payments within the UK, where terrorist financing risks can be more easily managed”.
3. NGOs must consider whether their activities are prohibited if they interact with designated people. “For example, simply meeting with a designated person, or providing them with a meal or a drink is unlikely to fall within the prohibitions whereas paying funds to the designated person or repaying a debt on their behalf are among the prohibitions that would apply”. Legislation does not prevent NGOs from operating overseas, including in areas where terrorist groups operate, but that it is the responsibility of NGOs and other organisations to “take reasonable steps to reduce the risk of non-compliance”.
4. The Government “acknowledges the negative impact” of bank account closures / restricted banking services on NGOs, but says that “neither the government nor regulators can compel banks or other financial institutions to offer an account to a particular customer. Decisions taken by bank are private and taken in accordance with their risk appetite and compliance with legal and regulatory requirements”. Individuals should “engage proactively with their bank at the earliest possible stage and provide information about their desired transactions, including how the ultimate use of the funds will be monitored. It may also be helpful for NGOs to demonstrate their existing due diligence processes”.
5. The risk of prosecution for terrorist offences for involvement in humanitarian work is low.

The guidance also has sections on proscribed organisations under the Terrorism Act, ransom payments, and BIS export control licences.