This ebulletin summarises recent developments in various international sanctions regimes. At EU level these are relatively limited:  

  • The EU has announced additional sanctions in respect of the situation in Syria, extending the designated persons list and announcing an imminent restriction on the export of jet fuel to Syria;
  • Minor amendments have also been made to the EU sanctions against Libya and Somalia; and
  • The EU has published two new sets of conclusions on the situation in Ukraine, but these do not discuss possible changes to the sanctions regime.  

In the UK, a new Overseas Territories Order extends the current EU sanctions relating to Russia/Ukraine to the British Overseas Territories including the Cayman and British Virgin Islands.  Updated guidance on the Russia trade sanctions has been issued by the Export Control Organisation. 

Syria sanctions

Under Council Implementing Regulation (EU) No 1105/2014 sixteen additional persons and two entities have been listed as subject to the Syrian asset freeze. The listed individuals are also subject to a travel ban. These measures took effect from 21 October 2014.

Twelve of the individuals listed are members of the Syrian Government including the Minister for Economy and Foreign Trade and the Minister for Communications and Technology. Mohamed Farahat, Vice President of Finance and Administration at Tri Ocean Energy and Abdelhamid Khamis Abdullah, Chairman of Overseas Petroleum Trading Company (OPT), are also included along with two senior figures in the Syrian armed forces.  The newly listed entities are Pangates International Corp Ltd for their role as intermediary in the supply of oil to the Syrian regime and its parent Abdulkarim Group.  HM Treasury has issued a notice in relation to these new designations.

The Council has also announced political agreement to impose an export ban on jet fuel and relevant additives exported to Syria. The legal acts bringing this agreement into force are yet to be adopted.

Libya sanctions

Under Council Regulation (EU) No 1102/2014 of 20 October 2014 the scope of the Libyan arms embargo has been amended so that the existing exemption permitting the provision of technical assistance, financing or financial assistance for security or disarmament assistance to the Libyan government only extends to assistance related to non-lethal military equipment.

The EU's grounds for designation under the existing asset freeze were also extended by Regulation 1102/2014 to include natural or legal persons, entities and bodies designated by the United Nations Security Council in accordance with Resolution (UNSCR) 2174 of 27 August 2014. This Resolution allows the UN to designate individuals or entities that it determines to be engaging in or providing support for acts that threaten the peace, stability or security of Libya, or obstruct or undermine the successful completion of its political transition.  No individuals or entities have yet been designated by the UN under its latest resolution and there have therefore been no changes to the EU's asset freeze list at this time.

Somalia sanctions

From 20 October 2014, Maalim Salman and Ahmed Diriye, respectively the head of African foreign fighters for al-Shabaab and the new emir of al-Shabaab, are subject to the asset freeze and the prohibition on providing investment services, and technical or financial assistance in relation to military activities or to the supply, sale, transfer, manufacture, maintenance or use of goods and technology included in the Common Military list of the EU. See Council Implementing regulation (EU) No 1104/2014 of 20 October 2014.

HM Treasury have also published a notice in respect of this development.

The situation in Ukraine/EU sanctions against Russia

At a Foreign Council meeting on 20 October 2014 the EU adopted various conclusions on Ukraine. These welcome the Minsk Protocol of 5 September and the Minsk Memorandum of 19 September as steps towards a sustainable political solution to the crisis and note the decreased overall level of violence as a result of the agreed ceasefire. However the conclusions are silent on the current sanctions regime.  

The European Council also adopted conclusions following its meetings on 23 and 24 October.  These recall the previous EU decisions on restrictive measures and note that the Council will "remain seized with the situation in Ukraine in order to provide further direction as required". The EU has previously indicated that a review of the current sanctions against Russia will take place by the end of October.

In relation to the existing sanctions regime,  the UK has issued a new Overseas Territories Order (The Russia, Crimea and Sevastopol (Sanctions) Overseas Territories) Order 2014 (SI 2014 No.2710)) which came into force on 16 October 2014. This Order gives effect in the specified Overseas Territories (including the Cayman Islands and the British Virgin Islands) to the trade sanctions imposed on Crimea, Sevastopol and Russia by the EU (see our previous briefing for further details of these measures).

The Export Control Organisation published updated FAQs on 30 September 2014 in relation to the EU Sanctions against Russia, which can be accessed here. Our briefing of 18 August  summarises the key points covered by the FAQs.  New information in the updated version includes:

  • Guidance on the definition of "associated services" prohibited in relation to deep water oil exploration and production, arctic exploration and production or shale oil projects in Russia and information regarding licenses for the carrying out of "associated services".
  • Guidance on the supply of goods including personnel and HR or payroll services to the oil industry in Russia.
  • Revised guidance on the provision of insurance and reinsurance for the transport of prohibited or restricted goods.
  • Limited guidance on the definition of "dual use items" and restrictions in exporting dual-use items to specific named entities.