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An analysis of U.S. OFAC SDN, EU, UK HMT and UN Consolidated Sanctions List
Frequency of list changes, volumes, affected entries and sanctions programs/regimes
The global sanctions landscape is changing rapidly – with direct impacts on business operations. For example, the high frequency of sanctions list changes needs to be reflected in the update cycles of the screening tools in place. Changing list volumes directly affect the hit processing in sanctions screening, either through additions/removals of listed parties or changes of existing entries. Other factors can have impacts as well such as the emergence of new regimes and their focus. This is an extract of the monthly sanctions analysis conducted by sanctions-intelligence.com.
Frequency of list changes, volumes, affected entries and programs in February 2020:
- There were 34 sanctions list amendments in February (January: 25 amendments), affecting 184 entries and 23 different sanctions programs/regimes.
- All four major sanctions lists increased by volume in February. Highest increases were Syria-related sanctions programs, or, in the case of OFAC SDN List, Venezuela-related. While 63 entries were added in total to the OFAC SDN list, 33 entries were removed at the same time, most of them related to the Foreign Narcotics Kingpin Sanctions Regulations [SDNTK].
- On Feb 21 2020, one entry with the content ‘Iranian Revolutionary Guard Corps’ was removed from the EU Consolidated List. Please note that there were two entries for this entity on the EU Consolidated List before, both referencing to legal basis 267/2012 (OJ L88) / IRN Programme. The other entry for the ‘Iranian Revolutionary Guard Corps’ (EU.2078.17) remained on the EU Consolidated Sanctions List. The reason for this amendment is unclear, possibly due to data harmonization purposes.
- On Feb 28 2020, the first two parties were listed under the ‘Turkey’-related sanctions on EU and UK Consolidated Lists. European Union: ‘Council Implementing Regulation (EU) 2020/274 of 27 February 2020 implementing Regulation (EU) 2019/1890 concerning restrictive measures in view of Turkey’s unauthorised drilling activities in the Eastern Mediterranean’ United Kingdom: Financial Sanctions Turkey.
Check relevance for your screening systems and seek professional advice where needed. This is an extract of the monthly analysis on U.S. OFAC SDN, EU, UK HMT and UN Consolidated Sanctions Lists conducted by sanctions-intelligence.com.
Sanctions-intelligence.com is a global information portal about sanctions updates, sanctions list characteristics, regular analyses and a market overview of sanctions-related products and services. Daily sanctions updates: www.sanctions-intelligence.com/list-changes
Reprinted with permission from GCRD international Dr. Pascal Ditté / sanctions-intelligence.com.