The U.K.'s Office of Financial Sanctions Implementation added 26 entries to its Russia sanctions regime and amended another 30 in yet another sanctions move against Russia following its invasion of Ukraine. The listed individuals include military officials, businessmen and relatives of listed individuals, such as Oleg Belozyorov, chief executive of Russian Railways; Nikolay Bodanovsky, a Russian army officer; Igor Korotchenko, chairman of the Russian Defense Ministry Public Council; and Boris Obnosov, executive at Tactical Missiles Corp.
The Office of Foreign Assets Control on April 20 issued guidance for holders of credit cards issued by sanctioned Russian financial institutions. The agency said U.S. operators of credit card systems are blocked from processing transactions involving certain sanctioned foreign financial institutions unless exempt by OFAC. Foreign operators of credit card systems whose payment cards are issued by sanctioned banks also risk violating U.S. sanctions if they allow those cards to be used in the U.S., OFAC said.
UserTesting, a California-based software company, said it may have violated U.S. sanctions by allowing users in Iran to access its platform, the company said in an April 4 SEC filing. The company said it conducted an internal review of its sanctions and export control compliance in “mid-2021” and discovered that Iranian “parties” signed up for a free trial of its platform but “did not make payment to us.” UserTesting also said it found a “limited number of participant accounts that represented themselves as residing in non-embargoed countries but may have accessed our platform from embargoed countries.”
The U.K. removed three entries and corrected another under its Iraq sanctions regime. According to the April 19 notice from the Office of Financial Sanctions Implementation, Maki Mustafa Hamudat, Asil Sami Mohammad Madhi Tabrah and Rasheed Bank were removed from the sanctions list. The entry for Omar Sabawi Ibrahim Hasan Al-Tikriti was also corrected to add Yemen as an address for the individual.
The Office of Foreign Assets Control issued Russia-related General License 27, which allows certain transactions by nongovernmental organizations involving Russia. The license authorizes activities in support of humanitarian projects, democracy building initiatives, education, non-commercial development projects and environmental and natural resource protection in both Russia and Ukraine.
Companies operating in Hong Kong should carefully monitor their transactions to make sure they’re not exposing themselves to Russia-related trade restrictions, which could lead to secondary sanctions, said Hong Kong-based law firm King & Wood. The recent string of international sanctions is “unprecedented” and effects are being felt “by businesses worldwide, including those in jurisdictions such as Hong Kong which has not issued any unilateral sanctions,” the firm said in an April 8 alert.
The State Department hasn’t ruled out designating Russia as a state sponsor of terrorism after being asked to do so by Ukrainian President Volodymyr Zelenskyy. The U.S. will “look at all potential options that are available to us under the law, options that would be effective in holding Russia to account,” spokesperson Ned Price told reporters April 18. Price said the U.S. has already imposed “unprecedented costs” on Russia, including sanctions and export controls, adding that if a “tool is available and effective, we won't hesitate to use it.”
Russia banned U.K. Prime Minister Boris Johnson and 12 senior British politicians from entering the country in response to U.K. sanctions on Russia following its invasion of Ukraine, the Russian Ministry of Foreign Affairs said in an April 16 statement, according to an unofficial translation. The individuals include former Prime Minister Theresa May and Deputy Prime Minister Dominic Raab.
The Office of Foreign Assets Control updated the sanctions entry for Lazarus Group, a North Korean cybercrime group designated in 2019 (see 1909130039). The agency didn’t release additional information.
In a series of sanctions moves, the U.K. corrected three entries under its ISIL (Da'esh) and al-Qaida sanctions regime and added two entries to its Russia sanctions list. Added to the Russia sanctions -- in response to its invasion of Ukraine -- by the U.K.'s Office of Financial Sanctions Implementation are Eugene Tenenbaum and David Davidovich, two associates of sanctioned businessman Roman Abramovich. In the ISIL notice, OFSI amended the entry for Ashraf Al-Qizani and corrected the entries for Mehrez Ben Mahmoud Ben Sassi Al-Amdouni, Mokhtar Belmokhtar and Ramzi Mohamed Abdullah Binalshibh.