The Export Controls & Sanction Manager - Edition 8 - 2023 - Week 50
- Arne Mielken
- Dec 20, 2023
- 10 min read
Stay Ahead of the Game: Key Insights from The Export Controls & Sanction Manager Edition 8 for Week 50 of 2023 - the last of 2023!
Welcome to the last "The Export Controls & Sanctions" Manager Magazine of the year. It's the perfect resource to help you stay fully compliant with export controls and sanctions laws across multiple jurisdictions. Don't miss out on our winter-themed edition and be confident in your compliance efforts - take a look today. We are a day late because we took a little more time to include the information on the latest sanctions packages of the EU and UK.
We are taking a break until 9 January 2024, and we look forward to serving you then and covering everything that happened between 21 December 2023 and 8 January 2024!
Wishing you a joyous and festive Merry Christmas and a prosperous and fulfilling Happy New Year in the year 2024!
Period covered 13.12 -20.12.2023

Content
Due Diligence & AML
U.S. Export Controls
EU Export Controls
UK Export Controls
Sanctions Updates
EU Sanctions
UK Sanctions
U.S. Sanctions
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Due Diligence & AML
For all updates, see: https://www.customsmanager.info/all-news/categories/due-diligence
NEW BLOG EXPLAINER Trade Compliance: A Comprehensive Guide for Custom and Global Trade Managers to Identify Red Flags
We have written a blog to assist you in discovering the secrets to navigating the complex landscape of customs and global trade management. The blog is a comprehensive guide that equips trade managers with the knowledge and tools they need to ensure compliance and avoid potential pitfalls. Read it here.
Export Controls Updates
To make sure you never miss an export control update, bookmark https://www.customsmanager.info/all-news/categories/export-controls
⇒ EU Export Controls
Updated EU Dual-Use Control List Comes Into Force”

The European Commission’s 2024 list of controlled dual-use items (proposed on 15 September 2023) has now come into force. The updates concern the control parameters for manufacturing equipment, high-performance computers and lasers, propulsion motors for submersible vehicles, and aircraft engines. We are proving you all the details and information of the changes so you can export compliantly
Details: https://www.customsmanager.info/post/eu-2023-update-of-the-eu-control-list-of-dual-use-items
⇒ UK Export Controls
Report of the 2023 UK ECJU Export Control Symposium
The 2023 ECJU Export Control Symposium was a highly anticipated event that brought together experts, policymakers, and industry leaders in the field of export control. We report on the main results and share PowerPoint Presentations for download.
⇒ U.S Export Controls
13 companies added to the U.S. EAR Unverified List
See names and updated here: https://www.customsmanager.info/post/u-s-export-controls-the-unverified-list
Implementation of the Chemical Weapons Convention
Legitimate Commercial Chemical, Biotechnology, and Pharmaceutical Activities Involving Schedule 1 Chemicals (including Schedule 1 Chemicals produced as Intermediates) During Calendar Year 2023. Date: 20 Dec 2023; Permalink
Sanctions Updates
The EU, UK and US implement extensive sanctions laws. These rules provide processes for producing lists of individuals and businesses subject to asset freeze targets and financial and investment restrictions. Businesses must stay up to date with the latest sanctions rules to avoid accidental non-compliance. Read the collection of all articles we have written on this topic here https://www.customsmanager.info/all-news/categories/sanctions
⇒ EU Sanctions Updates
EU Sanctions Against Russia: Content of the 12th Sanctions Package

The 12th round of sanctions against Russia has been adopted by the EU. It applies from 1 January 2024. This package aims to address loopholes, fight sanctions circumvention, and impose more import and export limitations on Russia.
EU Sanctions Against Russia: Full Guide (Updated)
Get a complete overview of EU sanctions against Russia, including the latest updates and a breakdown of each sanctions package. Date of last update 19.12.2023
EU: Consolidated Sanctions List of Persons, Groups, Entities, and Organisations (Sanctions) - Update
Discover the ultimate resource for EU sanctions: Download the consolidated list of persons, groups, and entities subject to sanctions. Date of last update 20.12.2023
EU Takes Action Against Sanctions Violations: Two New Initiatives Funded
Two new measures of the "Freeze and Seize" Task Force have reached political approval. We explain what this is all about.
⇒ UK Sanctions Updates
What You Need to Know About the UK's New Sanctions Against Russia

Regulations 2023: The Russia (Sanctions) (EU Exit) (Amendment) (No. 4) and The Russia (Sanctions) (Events) (Amendment) (No. 5) of Russia (Sanctions) (EU Exit) Regulations 2019 were amended by the UK government on December 14, 2023 to further restrict goods, technology, and funding sources that the UK government believes could be used to support Russia's war against Ukraine. The majority of the changes went into effect on December 15, 2023, with a few going into effect on December 26, 2023, and January 1, 2024.
Joint-Stock Commercial Bank Novikombank entry added, 27 entries amended on the consolidated list (19.12.2023)
The Joint-Stock Commercial Bank Novikombank (Group ID: 16337)has been added and 27 entries have been amended under the Russia financial sanctions regime. The Joint-Stock Commercial Bank Novikombank is now subject to an asset freeze, prohibitions on correspondent banking relationships and trust services sanctions. Details of the entity listings and amendments here.
7 entries added to the consolidated list
On 13 December 2023 the Foreign, Commonwealth and Development Office updated the UK Sanctions List . 7 entries have been added to the Counter-Terrorism (International) financial sanctions regime and are now subject to an asset freeze. You can access all the regimes that the uk has issued sanctions for here including links to latest updates.
OFSI General Licences updated
On 15 December 2023, OFSI updated the following General Licences to also permit activity that would otherwise breach the prohibitions in Regulation 17A of the Russia Regulations:
Transactions Related to Agricultural Commodities Including the Provision of Insurance and Other Services
Payments to Utility Companies for Gas and Electricity by UK Designated Persons who Own Payments to Companies House
Permitted Payments to UK Insurance Companies
Charities and Interim Managers and Trustees
Russia Travel for UK Nationals
Provision of Navigational Data to Civilian Aircrafts for Flight Safety
Prior Obligations
LCIA Payments
Payment to Water Companies for Water and Sewage
Legal Services
Emergency Payment(s) Directly or via an Intermediary to Belaeronavigatsia for Air Traffic Services
New UK Russia import sanctions updated

UK import sanctions against Russia were updated to reflect the implementation of new import sanctions measures relating to certain metals and diamond products. Our blog entry provides an overview of the import prohibitions in force on certain goods imported into the UK, including Northern Ireland, that have originated in or have been consigned from the territory covered by what is now the Russian Federation and non-government-controlled Ukrainian territory. It also sets out the licensing process for traders looking to import goods subject to prohibitions.
UK Guidance on third-country processed iron and steel measures Updated
Find out about the guide to relevant Russian iron and steel processed in third countries only, and the evidence traders need to provide to demonstrate compliance. It does not discuss other prohibitions (including other measures related to Russian iron and steel, except for the section on reuseable packaging under the GeneralTrade Licence).
Iran: First Designations under new UK sanctions law
The first round of sanctions under the new government targets the commander of Iran's Quds Force, the Islamic Revolutionary Guard Corps (IRGC), as well as anybody connected to Iran's support of Palestinian Islamic Jihad and Hamas. In agreement with the US, the new sanctions also place more limitations on Iran's drone project and shipping. The UK now has a great deal more authority to stop Iran's hostile actions both domestically and internationally thanks to the new sanctions framework. Read More....
The imposition of further sanctions by the UK on Iran has greatly increased the UK's ability to hold Iran and its leaders responsible.
OFSI publishes annual review 2022-2023
OFSI has published its annual review for the financial year 2022-2023, outlining (OFSI blog post): new sanctions which have been introduced in the last year, including new ransomware sanctions;
800 designated persons were added to the consolidated list;
as of April 2023, OFSI’s enforcement unit had 172 cases under live investigation;
OFSI recorded 473 suspected breaches of financial sanctions;
⇒ U.S. Sanctions Updates
U.S. Sanctions on Russia: A Look at the US Treasury's Impact Analysis
The US Treasury described how sanctions impact Russia's economy and offered policy recommendations on how to react. Read here
Treasury Targets Transnational Corruption
OFAC sanctioned two former Afghan government officials — Mir Rahman Rahmani (M. Rahmani) and his son, Ajmal Rahmani (A. Rahmani), collectively known as “the Rahmanis” — for their extensive roles in transnational corruption, as well as 44 associated entities.
The US names people and organisations associated with Russia's military-industrial complex.
Targeting third-country suppliers and procurement networks, OFAC has identified more than 150 people and organisations for allegedly providing Russia's military-industrial base. These people and organisations include:
a network of PRC-based companies headed by Hu Xiaoxun that purchases weapons made in China and supplies Russia with electronics and satellite photography technology;
7 Turkish companies that reportedly sent top-priority goods to producers in Russia;
8 UAE-based companies that have supplied Russia with materials, parts, and components for aircraft
Russia-related Designations and Designations Updates; Issuance of Russia-related General Licenses
OFAC is issuing Russia-related General License 79, "Authorizing the Wind Down of Transactions Involving Certain Entities Blocked on December 12, 2023," and Russia-related General License 80, "Authorizing Certain Transactions Related to Debt or Equity of, or Derivative Contracts Involving, Highland Gold Mining Limited." See more
U.S. And UK Target Additional Hamas Finance Officials and Representatives
OFAC imposed a fourth round of sanctions on Hamas since the October 7 terrorist attack on Israel. The action targets key officials who perpetuate Hamas’s violent agenda by representing the group’s interests abroad and managing its finances. OFAC closely coordinated with the United Kingdom to concurrently designate several key Hamas officials.
Other OFAC action
Please see below for details on these points
U.S. and U.K. Target IRGC-QF Support to Hamas and Other Proxy Groups
Treasury Sanctions Human Smuggling and Drug Trafficking Organization Operating on Southwest Border
Malas Manas chart
Burma General Licences 3 and 4 in the Federal Register
Publication of Burma Sanctions Regulations Web General Licenses 3 and 4 in 88 FR 87714, 19 Dec 2023. OFAC is publishing two general licenses (GLs) issued pursuant to the Burma Sanctions Regulations: GLs 3 and 4, each of which was previously made available on OFAC's website. GLs 3 and 4 were issued on March 25, 2021.
Publication of Syria-Related Sanctions Regulations Web General Licenses 1, 2, and 3 in 88 FR 87715, 19 Dec 2023
OFAC is publishing three general licenses (GLs) issued pursuant to the Syria-Related Sanctions Regulations: GLs 1, 2, and 3, each of which were previously made available on OFAC's website. GLs 1, 2, and 3 were issued on October 14, 2019.
Designation as Terrorist or Global Terrorist
Mohamed Ali Nkalubo and Ahmed Mahamud Hassan Aliyani Date: 20 Dec 2023; Permalink
Update of the latest SDN list (20.12.2023)
What if I have a question regarding these updates
We invite you to use the chat function available on www.customsmanager.org to ask any questions related to this update. Our skilled team of export control and sanctions managers will be happy to provide you with the information you need within 24 hours.
Sources
EU
Official Journal of the EU
DG TRADE Website
Social Media (LinkedIn, Twitter, etc).
Information on the National Export Control & Sanctions Website of Member States
U.S.
Bureau of Industry and Security (BIS)
Department of Commerce
Office of Foreign Asset Control (OFAC)
Social Media (LinkedIn, Twitter, etc).
UK
Information on gov.uk
Information on legislation.gov.uk
Department of Business and Trade
Social Media (LinkedIn, Twitter, etc).
Other
United Nations (Sanctions)
Social Media (LinkedIn, Twitter, etc).
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