In this issue:

- The Revised OFAC 50 Percent Rule

- U.S. and E.U. Sectoral Sanctions Targeting Russia

- Additional U.S. Sanctions Targeting Iran

- Sanctions Targeting Ongoing Conflicts in Syria, South Sudan, and the DRC

- Updates to Other U.S. and E.U. Sanctions Programs

- U.S. Enforcement Actions

- U.S. Counterterrorism and Counternarcotics Designations

- Annulment of E.U. Sanctions

- Excerpt from US and EU Issue and then Expand Sanctions Targeting Specific Sectors of the Russian -

Economy US SSI Sanctions -

In light of the ongoing conflict in Ukraine, on July 16, OFAC first issued sanctions pursuant to Executive Order (E.O.) 13662, which authorizes sanctions targeting specific sectors of the Russian economy (the SSI Sanctions). Additional entities were targeted pursuant to SSI Sanctions on July 29. Then, on September 12, OFAC amended the SSI Sanctions and expanded their scope, designating more SSI Entities in the process. The current landscape of the SSI Sanctions is detailed below. Each of the designated SSI Entities has been named pursuant to one or more of a total of four Directives, with each Directive containing specific restrictions. Overall, the SSI Sanctions effectively limit SSI Entities’ access to medium- and long-term US sources of funding. However, they do not impose blocking restrictions and do not prohibit US Persons1 from other dealings with SSI Entities; in fact, all transactions not expressly prohibited are permitted so long as no restrictions from other sanctions programs apply (e.g., if an SSI Entity has also been named as an SDN). US financial institutions are allowed to maintain correspondent accounts and process US dollar-clearing transactions for SSI Entities, insofar as those activities do not involve debt or equity transactions prohibited under SSI Sanctions. The prohibitions created by the SSI Sanctions also extend to debt and equity issued by entities that are 50 percent or more owned by SSI Entities (applying the new aggregation rule from OFAC).