Sanctions after Brexit

https://brexit.law/2018/05/14/sanctions-after-brexit/
Sanctions after Brexit

This event explores the impact of Brexit on economic sanctions from different perspectives – law, policy, and industry. The first panel will discuss the new legal framework in the UK, the second will look at policy implications and sanctions relationships between the UK and the rest of the world (including the EU, UN and USA), and the third panel will examine the impact on industry and trade, including compliance and licensing. Please come with questions – the evening will be largely conversational and (we hope!) lively Q&A with our enormously experienced panelists, continued at a drinks reception afterwards.

Time: 4.30 PM – 7 PM then a drinks reception

Date: Thursday, 21st June 2018

Venue: The Lancaster Room
The Savoy (The River Entrance via Savoy Place off Victoria Embankment)
London
WC2R 0BP

LAW
Chair: Maya Lester QC, Brick Court Chambers
Giles Thomson, Deputy Director, Sanctions and Illicit Finance, HM Treasury
Miriam Gonzalez, Partner and Co-Chair of the International Trade and Government Regulation Practice, Dechert LLP
Nicky Smith, Deputy Director, Foreign & Commonwealth Office Legal Directorate
Chloe Cina, Lawyer and Sanctions Expert, former UK Head of Sanctions at HSBC
David Mortlock, Partner, Chair of Global Trade & Investment Group, Wilkie Farr & Gallagher LLP
David Heaton, Brick Court Chambers

POLICY
Chair: David Anderson QC, Brick Court Chambers
Sir John Sawers, former Chief of the Secret Intelligence Service (MI6)
Harold Hongju Koh, Former Legal Adviser of the US Department of State
Kimberly Prost, Canadian Judge on the International Criminal Court, former Ombudsperson for the UN Security Council Al-Qaeda Sanctions Committee
Qudsi Rasheed, Deputy Director Sanctions, Foreign & Commonwealth Office
Manuel Lafont Rapnouil, Head of the Paris office and Senior Policy Fellow, European Council on Foreign Relations
Dr Erica Moret, Senior Researcher at the Global Governance Centre at the Graduate Institute of International and Development Studies
David Meale, Acting Deputy Assistant Secretary for Counter Threat Finance and Sanctions, US Department of State

INDUSTRY
Chair: Maya Lester QC, Brick Court Chambers
Susan Lake, Head of Compliance Reinsurance EMEA, Swiss Re
Andy Wragg, Global Chief Compliance Officer, AXA Corporate Solutions
Che Sidanius, Global Head of Regulation & Industry Affairs, Thomson Reuters
William Dodsworth, Head of Financial Crime Policy, Barclays
Tom Keatinge, Director, RUSI’s Centre for Financial Crime & Security Studies
Peter Dale-Skinner, Head of Compliance, Office of Financial Sanctions Implementation

Pubblicato in sanctions, sanzioni | Lascia un commento

Illegal annexation of Crimea and Sevastopol: EU extends sanctions by one year. Annessione illegale della Crimea e di Sebastopoli: l’UE proroga le sanzioni di un anno.

Il 18 giugno 2018 il Consiglio ha prorogato fino al 23 giugno 2019 le misure restrittive in risposta all’annessione illegale della Crimea e di Sebastopoli da parte della Russia.

http://www.consilium.europa.eu/it/press/press-releases/2018/06/18/illegal-annexation-of-crimea-and-sevastopol-eu-extends-sanctions-by-one-year/

http://www.consilium.europa.eu/en/press/press-releases/2018/06/18/illegal-annexation-of-crimea-and-sevastopol-eu-extends-sanctions-by-one-year/

Pubblicato in sanctions, sanzioni | Lascia un commento

Banca d’Italia: Attuazione della politica monetaria ed Emergency Liquidity Assistance

Attuazione della politica monetaria ed Emergency Liquidity Assistance

La Banca d’Italia concorre a formulare la politica monetaria nell’area dell’euro attraverso la partecipazione del Governatore al Consiglio direttivo della Banca centrale europea (BCE). In qualità di membro del Consiglio direttivo, il Governatore della Banca d’Italia agisce in piena autonomia e indipendenza, contribuendo alle decisioni di politica monetaria anche sulla base dell’attività preparatoria condotta dai comitati e dai gruppi di lavoro dell’Eurosistema cui partecipano rappresentanti dell’Istituto. In virtù dei principi di decentramento operativo e sussidiarietà stabiliti a livello europeo, la Banca d’Italia partecipa all’attuazione della politica monetaria.

Pubblicato in ecosec | Lascia un commento

La Corte di giustizia conferma il mantenimento del congelamento di capitali di Rami Makhlouf, cugino di Bachar al-Assad, per il periodo 2016-2017. The Court of Justice confirms that the fund-freezing measures imposed on Rami Makhlouf, cousin of Bashar al-Assad, must be maintained for the period 2016-2017.

Sentenza nella causa C-458/17 Rami Makhlouf / Consiglio
14 giugno 2018

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Bilancio UE: all’Europa che protegge 4,8 miliardi di € in finanziamenti per la sicurezza

IP-18-4125_IT

Per il prossimo bilancio a lungo termine dell’UE per il periodo 2021-2027 la Commissione propone un consistente aumento degli attuali finanziamenti destinati alla sicurezza: da 3,5 a 4,8 miliardi di €.

IP-18-4121_IT

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EMN: Annual Report on Migration and Asylum 2017

Annual Report on Migration and Asylum 2017

The effectiveness of return in EU Member States

The changing influx of asylum seekers in 2014- 2016: Member State responses Common Template of EMN Focussed Study 2017

Safe Country of Origin

Italy country factsheet_2016_en

Pubblicato in protezione internazionale | Lascia un commento

Ad-Hoc Query on Average cost and average length of reception for asylum seekers

Ad-Hoc Query on Average cost and average length of reception for asylum seekers

Pubblicato in protezione internazionale | Lascia un commento

The Charlevoix G7 Summit (almost) Joint Communique

The Charlevoix G7 Summit Communique

“4. We acknowledge that free, fair, and mutually beneficial trade and investment, while creating reciprocal benefits, are key engines for growth and job creation. We recommit to the conclusions on trade of the Hamburg G20 Summit, in particular, we underline the crucial role of a rules-based international trading system and continue to fight protectionism. We note the importance of bilateral, regional and plurilateral agreements being open, transparent, inclusive and WTO-consistent, and commit to working to ensure they complement the multilateral trade agreements. We commit to modernize the WTO to make it more fair as soon as possible. We strive to reduce tariff barriers, non-tariff barriers and subsidies.”

Pubblicato in trade, trade wars, WTO | Lascia un commento

1970 Libya Sanctions Committee adds leaders of a transational trafficking network or involved in brutal treatment of migrants to its sanctions list .

http://www.whatsinblue.org/2018/06/libya-reauthorisation-of-maritime-interdiction-and-addition-of-names-to-sanctions-list.php

1970 Libya Sanctions Committee adds individuals to its sanctions list

The six names were proposed by the Netherlands, supported by France, the UK, the US, and non-Council member Germany, for human rights abuses against migrants. They are the first new individuals to be designated for sanctions (travel ban and asset freeze) by the Libya Sanctions Committee, established by resolution 1970 (2011), since June 2011. In June 2015, two names were proposed for listing in the context of undermining the successful completion of Libya’s political transition. The names were put forward by France, Spain, the UK and the US, but silence was broken by China and Russia, effectively blocking the listing.

The sanctions against the individuals went into effect on 7 June under the listing criterion related to human rights abuses, pursuant to paragraph 22(a) of resolution 1970 (2011), paragraph 4(a) of resolution 2174 (2014) and paragraph 11(a) of resolution 2213 (2015). Four of the individuals (including two Libyan nationals and two Eritrean nationals) are leaders of a transnational trafficking network. One of these Libyan nationals also commands a militia involved in brutal treatment of migrants. A fifth is a Libya national who serves as the Commander of the Shuhada al-Nasr brigade and head of the Petrol Refinery Guard of Zawiya’s refinery, a central hub of migrant smuggling operations. A sixth, also a Libyan national, is the Commander of the regional Coast Guard in Zawiya.

The proposed listings were first put under silence procedure at the beginning of May.
At that time, the listings were explicitly supported by Libya and all Council members except Russia. Before the end of the silence procedure, Russia put a “technical hold” on the listings and asked for more information as well as the convening of a formal Committee meeting. It seems that Russia’s concerns were related to its generally cautious attitude towards the imposition of sanctions and their effectiveness. In addition, Russia inquired about potential national criminal proceedings against the targeted individuals and the role of nationals from countries of origin and destination in trafficking activities.

The Committee meeting requested by Russia took place on 25 May, with a representative from the Libyan delegation in New York present for part of the meeting to answer questions. The main argument from the member states that proposed the listings was that criminal networks profiting from migrant abuse threaten the peace, stability and security of Libya. The general belief was that Russia would not block the listings, considering that Libya and the African members of the Council supported them. Russia lifted their hold on 7 June.”

The 1970 Committee is mandated to consider designating individuals or entities on the basis of the criteria contained in paragraph 22 of resolution 1970 (2011), paragraph 23 of resolution 1973 (2011), paragraph 11 of resolution 2146 (2014), paragraph 4 of resolution 2174 (2014) paragraph 11 of resolution 2213 (2015) and paragraph 11 of resolution 2362 (2017).

https://www.un.org/sc/suborg/en/sanctions/1970

https://scsanctions.un.org/fop/fop?xml=htdocs/resources/xml/en/consolidated.xml&xslt=htdocs/resources/xsl/en/libya.xsl

Resolution 2362 (2017)
Resolution 2213 (2015)
Resolution 2174 (2014)
Resolution 2146 (2014)
Resolution 1973 (2011)
Resolution 1970 (2011)

LYi.024 Name: 1: MUS’AB 2: ABU-QARIN 3: na 4: na
Title: na Designation: Leader of a transnational trafficking network DOB: 19 Jan. 1983 POB: Sabratha, Libya Good quality a.k.a.: na Low quality a.k.a.: a) ABU-AL QASSIM OMAR Musab Boukrin b) The Doctor c) Al-Grein Nationality: Libya Passport no: a) 782633, issued on 31 May 2005 b) 540794, issued on 12 Jan. 2008 National identification no: na Address: na Listed on: 7 Jun. 2018 Other information: Listed pursuant to paragraphs
15 and 17 of resolution 1970 (Travel Ban, Asset Freeze) INTERPOL-UN Security Council Special Notice web link: https://www.interpol.int/en/notice/search/un/

LYi.022 Name: 1: Fitiwi 2: Abdelrazak 3: na 4: na
Name (original script): ### ###### (Tigrinya)
Title: na Designation: Leader of a transnational trafficking network DOB: Approximately (30-35 years old) POB: Massaua, Eritrea Good quality a.k.a.: na Low quality a.k.a.: Fitwi Esmail Abdelrazak Nationality: Eritrea Passport no: na National identification no: na Address: na Listed on: 7 Jun. 2018 Other information: Listed pursuant to paragraphs 15 and 17 of resolution 1970 (Travel Ban, Asset Freeze)

LYi.021 Name: 1: Ermias 2: Ghermay 3: na 4: na
Name (original script): ##### #### (Tigrinya)
Title: na Designation: Leader of a transnational trafficking network DOB: Approximately (35-45 years old) POB: (possibly Asmara, Eritrea) Good quality a.k.a.: na Low quality a.k.a.: a) Ermies Ghermay b) Ermias Ghirmay Nationality: Eritrea Passport no: na National identification no: na Address: (Known address: Tripoli, Tarig
sure no. 51, likely moved to Sabratha in 2015.) Listed on: 7 Jun. 2018 Other information: Listed pursuant to paragraphs 15 and 17 of resolution 1970 (Travel Ban, Asset Freeze)

LYi.025 Name: 1: Mohammed 2: Kachlaf 3: na 4: na
Title: na Designation: Commander of the Shuhada al-Nasr brigade, Head of the Petrol Refinery Guard of Zawiya’s refinery DOB: na POB: Zawiya, Libya Good quality a.k.a.: na Low quality a.k.a.: a) Kashlaf b) Koshlaf c) Keslaf d) al-Qasab Nationality: Libya Passport no: na National identification no: na Address: Zawiya, Libya Listed on: 7 Jun. 2018 Other information: Listed pursuant to paragraphs 15 and 17 of resolution 1970 (Travel Ban, Asset Freeze)

LYi.023 Name: 1: Ahmad 2: Oumar 3: al-Dabbashi 4: na
Title: na Designation: Commander of the Anas al-Dabbashi militia, Leader of a transnational trafficking network DOB: Approximately (30 years old ) POB: (possibly Sabratha, Talil neighbourhood) Good quality a.k.a.: na Low quality a.k.a.: a) Al-Dabachi b) Al Ammu c) The Uncle d) Al-Ahwal Nationality: Libya Passport no: na National identification no: na Address: a) Garabulli, Libya b) Zawiya, Libya Listed on: 7 Jun. 2018 Other information: Listed pursuant to paragraphs 15 and 17 of resolution 1970 (Travel Ban, Asset Freeze) INTERPOL-UN Security Council Special Notice web link: https://www.interpol.int/en/notice/search/un/

LYi.026 Name: 1: Abd 2: Al-Rahman 3: al-Milad 4: na
Title: na Designation: Commander of the Coast Guard in Zawiya DOB: Approximately (29 years old) POB: Tripoli, Libya Good quality a.k.a.: na Low quality a.k.a.: a) Rahman Salim Milad b) al-Bija Nationality:
Libya Passport no: na National identification no: na Address: Zawiya, Libya Listed on: 7 Jun. 2018 Other information: Listed pursuant to paragraphs 15 and 17 of resolution 1970 (Travel Ban, Asset Freeze) INTERPOL-UN Security Council Special Notice web link: https://www.interpol.int/en/notice/search/un/

Pubblicato in Lybia, sanctions | Lascia un commento

Golden power: Next Ingegneria dei Sistemi s.p.a. / Defence Tech Holding s.r.l.

Il Consiglio dei ministri ha deliberato:

di esercitare, a tutela degli interessi essenziali della difesa e della sicurezza nazionale, i poteri speciali, con l’imposizione di condizioni e prescrizioni, in relazione all’operazione di acquisizione delle azioni costituenti l’intero capitale sociale della Next Ingegneria dei Sistemi s.p.a. da parte della società Defence Tech Holding s.r.l.;
di esercitare i poteri speciali con riferimento alla modifica della governance della società Reti Telematiche Italiane s.p.a derivante dall’assemblea degli azionisti del 27 aprile 2018, mediante l’imposizione di prescrizioni e condizioni volte a salvaguardare le attività strategiche della società nel settore delle comunicazioni.

Pubblicato in Golden Power | Lascia un commento

JCPOA: a joint letter from Europe to USA

To: Steven MNUCHIN, Secretary of the Treasury, The United States of America
and Mike POMPEO, Department of State, The United States of America

Dear colleagues,
We strongly regret the decision taken by the United States to withdraw from the Joint Comprehensive Plan of Action (JCPoA). We believe that the JCPoA, which was unanimously endorsed by the UN Security Council, is critical for protecting our collective security interests.
Even though the United States has decided to withdraw from the JCPoA, we are still convinced that the JCPoA is the best means through which we can prevent a nuclear- armed Iran. There appears to be no credible alternatives at this time. As such, an Iranian withdrawal from the JCPoA would further unsettle a region where additional conflicts would be disastrous. We share most of the concerns expressed by the US regarding the status of Iran’s nuclear programme after 2025, Iran’s ballistic missiles programme, and its destabilising actions in the region. We believe that preserving the content of the JCPoA is the best basis on which to engage Iran and address these concerns.
As allies, we expect that the United States will refrain from taking action to harm Europe’s security interests. The E3 and the EU are committed to undertaking strong efforts to continue sanctions relief to Iran in order to uphold our commitments to the JCPoA for as long as Iran remains in compliance with its requirements. As you know, the International Atomic Energy Agency has recently confirmed for the 11th time that this remains the case. We therefore ask for your assurances that the US will not take actions that might undermine the ability to do this in line with UNSCR 2231. In their current state, US secondary sanctions could prevent the European Union from continuing meaningful sanctions relief to Iran.
Building on our discussions at several occasions, as close allies we expect that the extraterritorial effects of US secondary sanctions will not be enforced on EU entities and individuals, and the United States will thus respect our political decision and the good faith of economic operators within EU legal territory.
In support of this, we specifically request you to:
– grant exemptions from US sanctions for EU companies that initiated or concluded their contracts after JCPoA Implementation Day (16 January 2016).
– give public confirmation of areas of business that are exempt from US secondary sanctions, such as pharmaceuticals, healthcare; and grant exemptions to allow for economic relationships in key sectors, in particular in the fields of energy, automotive, civil aviation and infrastructure.
– grant exemptions to maintain banking channels and financing channels with Iran. This notably includes maintaining links with the Central Bank of Iran as well as with the other Iranian banks that are not sanctioned by the European Union and the preservation of financial messaging services (SWIFT) to these banks.
– grant extended and adapted winding-down periods according to the necessary time to properly wind down affected projects for companies that may eventually choose to withdraw from Iran.
– prolong General License H (foreign subsidiaries of US companies to be able to continue business).
– reaffirm the exemption for Embassy bank accounts.
Please note that these first requests are preliminary and do not aim to cover those that OFAC will directly receive from European companies. Our authorities stand ready to support them in this process.
We are sure that, building on our steadfast cooperation, we will manage to find swift and efficient remedies to these urgent concerns. Therefore, the E3 and the EU would welcome a constructive approach on the issues set above. Following this, we are ready to continue working together with you on matters of shared concern.
Sincerely yours,

Bruno Le Maire
Olaf Scholz
Philip Hammond
Heiko Maas
Jean-Yves Le Drian
Peter Altmaier
Boris Johnson

Joint E3 letter on JCPoA

Pubblicato in natsec, sanctions, sanzioni | Lascia un commento