The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 16 Oct 2023 (UK):
The Foreign, Commonwealth and Development Office ("FCDO") issued an e-alert following the Court of Appeal's judgement in the case of Mints & others v PJSC National Bank Trust & another.
This was alert was issued in response to obiter in the case of Mints, which suggested that National Bank Trust ("NBT") should be treated as subject to the asset freeze by virtue of being owned or controlled by one or more DPs within the meaning of Regulation 7(4) of the Russia (Sanctions) (EU Exit) Regulations 2019, namely Vladimir Putin, the President of the Russian Federation, and Elvira Nabiullina, the Governor of the Central Bank of Russia ("CBR"). In January 2023, the High Court found that control held through political office fell outside Regulation 7(4), so Putin and Nabiullina did not control the CBR. However, the Court of Appeal concluded that NBT, and by implication the CBR, is controlled by Putin and/or Nabiullina for the purpose of the UK sanctions regime. However, the Court's findings on the ownership and control issue were obiter and so are non-binding on subsequent courts and UK persons. The FCDO has now issued a clarifying statement on the position.
The OverRuled: China Trade Controls Resource Center has been updated with the following actions:
- 18 Oct 2023 (OFAC):
OFAC designated three entities and one individual in Hong Kong, as well as two individuals in the PRC, pursuant to EO 13382, among other parties based in Iran and Venezuela pursuant to EO 13382 and EO 13949, for enabling Iran's destabilizing ballistic missile and unmanned aerial vehicle ("UAV") programs. The parties have materially supported Iran's Islamic Revolutionary Guard Corps, Ministry of Defense, and Armed Forces Logistics, or their subordinates in the production and proliferation of missiles and UAVs.
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