Autonomous Sanctions (Designated Persons and Entities and ...
The net change -in designated entities was14
1
United Nations OFAC Most updates were to modify existing sanctions regimes and targeted entities There was a strong focus on Al-Qaeda sanctions regimes The net change in designated entities was -14 Week 1 Week 2 Week 3 Week 4 Week 5 Week 6 Week 7 Week 8 Week 9 Week 10 Week 11 Week 12 Week 13 0 0.5 1 1.5 Number of updates Number of records 2 2.5 0 40 80 120 160 20 60 100 140 180 0 0.5 1 1.5 Number of updates Number of records 2 2.5 0 20 40 60 10 30 50 70 It was a busy quarter for OFAC, which issued a significant amount of new designations Designations touched multiple sanctions programs, but there was a particular focus on Iran 3 3.5 4 4.5 Week 1 Week 2 Week 3 Week 4 Week 5 Week 6 Week 7 Week 8 Week 9 Week 10 Week 11 Week 12 Week 13 Al-Qaeda DR Congo Libya Sudan Mali Iraq Central African Republic Yemen 1 1 1 2 2 2 2 9 OFAC record changes spiked in Week 2 due to the Iran-Saudi Arabia military skirmish. Removals peaked in Week 7 due to the lifting of sanctions against entities linked to Somali terrorist groups. UN sanctions have been very slow since Week 4. There have been no additions in the last 3 weeks of March. Number added Number modified Number deleted UN Number added Number modified Number deleted OFAC Taking the pulse of major sanctions lists: January—March 2020 The net change in designated entities was +68 Iran-Saudi Arabia military skirmish UN 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% OFAC EU UN=13 updates OFAC=22 updates EU=16 updates More than ever, being equipped with quality list data is essential for sanctions compliance programs – contact us or visit the Firco Global WatchList product page to learn more about how Accuity can support your team. European Union Overall changes between January–March Most updates were to modify existing entities, but there were also a number of new designations The changes touched a range of sanctions programs across the board Week 1 Week 2 Week 3 Week 4 Week 5 Week 6 Week 7 Week 8 Week 9 Week 10 Week 11 Week 12 Week 13 0 0.5 1 1.5 Number of updates Number of records 2 2.5 0 40 80 120 20 60 100 140 3 3.5 4 4.5 Key takeaways Sanctions activity has levelled off in Q1 2020 from FY 2019 (and its 9% growth rate for OFAC). OFAC regulatory priorities indicate increased divergence from EU, UN, and the broader international community, particularly in regard to Iran sanctions. EU and UN sanctions have seen diminished activity since late January. This coincides with the peak of the Coronavirus pandemic in China and the subsequent spread elsewhere. The coronavirus has not stopped regulatory activity outright; OFAC in particular continues to issue new sanctions. EU sanctions have been erratic, but generally low in changes since Week 5. A Week 11 spike corresponds with the renewal of Ukraine sanctions. 160 180 Iran Venezuela Terrorism Ukraine Non-proliferation North Korea Human Rights & Corruption Narcotics Trafficking Nicaragua Cyber-crime South Sudan Zimbawe Syria 1 1 2 2 6 16 1 3 Al-Qaeda Mali Ukraine Taliban Belarus Turkey Libya Zimbabwe Syria DR Congo Somalia Tunisia Iraq Terrorism Egypt Central African REP. 1 1 2 1 1 2 2 2 2 1 1 3 3 1 3 2 Number added Number modified Number deleted EU Number added Number modified Number deleted The net change in designated entities was +11 UN Sanctions against those groups had been lifted for quite some time, and some analysts link the removal to intense lobbying effort from the Somali entities. Interestingly, an OFAC enforcement from early 2020 referred precisely to the provision of lobbying services to those Somali entities (AL BARAKAT – enforcement action against “Park Strategies LLC”.)” The week 11 update corresponds to a renewal of an existing sanctions regime (Ukraine), with updated details on list records. EU restrictive measures are imposed (and renewed) on a yearly basis, so there is a ‘seasonal effect’ in EU Sanctions.” COVID-19 may have factored into this trend. Since UNSC Resolutions require permanent members to vote, some countries may have had little political availability for those matters.” Accuity analyzed sanctions data from the core regulators to reveal trends in policy during the first quarter of 2020. 3 3 5 7 3
Transcript of The net change -in designated entities was14
United Nations
OFAC
Most updates were to modify existing sanctions regimes and targeted entities
There was a strong focus on Al-Qaeda sanctions regimes
The net change in designated entities was
-14
Week 1
Week 2
Week 3
Week 4
Week 5
Week 6
Week 7
Week 8
Week 9
Week 10
Week 11
Week 12
Week 13
0
0.5
1
1.5
Number of updates Number of records
2
2.5
0
40
80
120
160
20
60
100
140
180
0
0.5
1
1.5
Number of updates Number of records
2
2.5
0
20
40
60
10
30
50
70
It was a busy quarter for OFAC, which issued a significant amount of new designations
Designations touched multiple sanctions programs, but there was a particular focus on Iran
3
3.5
4
4.5
Week 1
Week 2
Week 3
Week 4
Week 5
Week 6
Week 7
Week 8
Week 9
Week 10
Week 11
Week 12
Week 13
Al-Qaeda DR Congo
Libya
Sudan
Mali
Iraq
Central African Republic
Yemen
11
1
2
2
2
29
OFAC record changes spiked in Week 2 due to the Iran-Saudi Arabia military skirmish. Removals peaked in Week 7 due to the lifting of sanctions against entities linked to Somali terrorist groups.
UN sanctions have been very slow since Week 4. There have been no additions in the last 3 weeks of March.
Number added
Number modified
Number deleted
UN
Number added
Number modified
Number deleted
OFAC
Taking the pulse of major sanctions lists: January—March 2020
The net change in designated entities was
+68
Iran-Saudi Arabia military skirmish
UN
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
OFAC
EU
UN=13 updates
OFAC=22 updates
EU=16 updates
More than ever, being equipped with quality list data is essential for sanctions compliance programs – contact us or visit the Firco Global WatchList product page to learn more about how Accuity can support your team.
European Union
Overall changes between January–March
Most updates were to modify existing entities, but there were also a number of new designations
The changes touched a range of sanctions programs across the board
Week 1
Week 2
Week 3
Week 4
Week 5
Week 6
Week 7
Week 8
Week 9
Week 10
Week 11
Week 12
Week 13
0
0.5
1
1.5
Number of updates Number of records
2
2.5
0
40
80
120
20
60
100
140
3
3.5
4
4.5
Key takeaways
Sanctions activity has levelled off in Q1 2020 from FY 2019 (and its 9% growth rate for OFAC).
OFAC regulatory priorities indicate increased divergence from EU, UN, and the broader international community, particularly in regard to Iran sanctions.
EU and UN sanctions have seen diminished activity since late January. This coincides with the peak of the Coronavirus pandemic in China andthe subsequent spread elsewhere.
The coronavirus has not stopped regulatory activity outright; OFAC in particular continues to issue new sanctions.
EU sanctions have been erratic, but generally low in changes since Week 5. A Week 11 spike corresponds with the renewal of Ukraine sanctions.
160
180
Iran
Venezuela
Terrorism
Ukraine
Non-proliferation
North Korea
Human Rights & Corruption
Narcotics Trafficking
Nicaragua
Cyber-crime
South Sudan
Zimbawe
Syria
1
1
2
2
6
161
3
Al-Qaeda
Mali
Ukraine
Taliban
Belarus
Turkey
Libya
Zimbabwe
Syria
DR Congo
Somalia
Tunisia
Iraq
Terrorism
Egypt
Central African REP.
1
1
2
11
2
2
2
2
11 3
3
1
3
2
Number added
Number modified
Number deleted
EU
Number added Number modified Number deleted
The net change in designated entities was
+11
UN Sanctions against those groups had been lifted for quite some time, and some
analysts link the removal to intense lobbying effort from the Somali entities. Interestingly, an OFAC enforcement from early 2020 referred precisely to the provision of lobbying services to those Somali entities (AL BARAKAT – enforcement action against “Park Strategies LLC”.)”
The week 11 update corresponds to a renewal of an existing sanctions regime
(Ukraine), with updated details on list records. EU restrictive measures are imposed (and renewed) on a yearly basis, so there is a ‘seasonal effect’ in EU Sanctions.”
COVID-19 may have factored into this trend. Since UNSC Resolutions require
permanent members to vote, some countries may have had little political availability for those matters.”
Accuity analyzed sanctions data from the core regulators to reveal trends in policy during the first quarter of 2020.
33 5
7
3
![· Web viewPolicy Manual— [October 2014] * July 1, 2017 ... providers of services under the Medicaid program under title XIX of the Social Security Act, entities designated by](https://static.fdocuments.in/doc/165x107/5c23407209d3f2ce4c8b85f2/-web-viewpolicy-manual-october-2014-july-1-2017-providers-of-services.jpg)
