Monthly Archives: January 2024

Australia has used cyber sanctions on a Russian hacker

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The Australian Government has imposed a targeted financial sanction and a travel ban on Aleksandr Ermakov.

According to the Australian government, he was involved in the breach of the Medibank Private network (Medibank is a health company providing private health insurance and health services to more than 3.9 million people in Australia).

In the attack, 9.7 million records were stolen. These records included names, dates of birth, Medicare numbers, and sensitive medical information. Some records were published on the dark web.

This sanction makes it a criminal offence, punishable by up to 10 years’ imprisonment and heavy fines, to provide assets to Aleksandr Ermakov (also known as GustaveDore; aiiis_ermak, blade_runner, JimJones) or to use or deal with his assets, including through cryptocurrency wallets or ransomware payments.

“We continue to work with our friends and partners around the world to ensure cyber criminals are held to account for their actions and we will relentlessly pursue activities which disrupt their capability to target Australians in the cyber space.”

Deputy Prime Minister, the Hon Richard Marles MP

The European Union has banned an advisor to Syrian leader

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The Council of the EU has approved additional restrictive measures against 6 persons and 5 syrian entities.

The new listings include an economic advisor to Syrian leader Bashar al-Assad, three leading businesspersons providing support to, and benefitting from, the Syrian regime and two persons connected to the Assad family.

The following persons and entities are added to the sanction list:

  • Yasser Hussein Ibrahim. He is an economic advisor to Bashar al-Assad and acts in the economic council run by Asma al-Assad. Together with Ali Najib Ibrahim he operates a number of shell companies, and acts as a front for business activities of Bashar Al-Assad and Asma Al-Assad.
  • Mahmoud al-Dj. Mahmoud al-Dj is a leading businessperson operating in Syria, who owns several companies active in different sectors such as logistics and tourism. He facilitates illicit transactions between regime-affiliated persons and entities in Syria and Eastern Libya.
  • Bilal al-Naal. He is a founder and partner of multiple trading and investment companies in Syria.
  • Fahad Darwish. Darwish owns and runs multiple businesses in Syria active in different sectors such as trading and pharmaceuticals.
  • Mohannad al-Dabbagh. Mohannad al-Dabbagh is a cousin of Asma al-Assad. He co-owns Takamol LLC, a company responsible for managing the electronic “smart card program” used since 2014 to distribute subsidised food and other products in Syria.
  • Firas al-Akhras. Firas al-Akhras is the brother of Asma al-Assad. He is co-owner of the Takamol LLC company responsible for managing the electronic “smart card program” used since 2014 to distribute subsidised food and other products in Syria.
  • Al-Dj Group. Al-Dj Group is a Syrian business entity, owned and managed by Mahmoud al-Dj. As a holding company it owns and operates the Freebird Travel Agency, an agent for Cham Wings Airlines, which is conducting frequent flights between Syria and Libya.
  • Cham Wings. Cham Wings Airlines is a Syrian business entity which is owned by Muhammad Issam Shammout.
  • Freebird Travel Agency. Freebird serves as principal agent for Cham Wings Airlines.
  • Iloma Investment Private JSC. Iloma Investment Private JSC has been established at the beginning of 2023 to take over almost half of the ownership of Damascus airport.
  • Al-Aqila Company. Al-Aqila Company entered into a joint venture with the Iranian Alborz Insurance Company

Sanctions on Syria were first introduced in 2011 in response to the violent repression of the civilian population. EU sanctions target the Assad regime and its supporters, as well as sectors of the economy from which the regime makes profit.

The Council of the EU has added six entities from Sudan to EU sanctions list

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The Council of the EU has raised new measures against six entities, in view of the gravity of the situation in Sudan. Nowadays, in Sudan are fighting between the Sudanese Armed Forces (SAF) and the Rapid Support Forces (RSF) and their respective affiliated militias.

The new sanctions lists include six entities responsible for supporting activities undermining the stability and political transition of Sudan.

Among the entities listed are two companies involved in the manufacture of weapons and vehicles for the SAF (Defense Industries System and SMT Engineering); the SAF-controlled Zadna International Company for Investment Limited and three companies involved in procuring military equipment for the RSF (Al Junaid Multi Activities Co Ltd, Tradive General Trading and GSK Advance Company Ltd).

The entities listed are subject to asset freezes. The provision of funds or economic resources, directly or indirectly, to them or for their benefit is prohibited.

According to the United States Agency for International Development, conflict that exploded between Sudanese Armed Forces and the paramilitary Rapid Support Forces on April 15, 2023, has created the world’s largest internal displacement crisis, with 5.1 million people displaced in Sudan between April and November 2023.

Businessman arrested for scheme to illegally export semiconductors to Russia

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Ilya Kahn, 66, a citizen of the United States, Israel and Russia was arrested in Los Angeles for his alleged involvement in a years-long scheme to secure and unlawfully export sensitive technology from the United States for the benefit of a Russian business, the United States Department of Justice said.

The business was sanctioned by the U.S. government following Russia’s invasion of Ukraine in February 2022. According to court documents, Kahn is charged by criminal complaint with conspiracy to violate the Export Control Reform Act (ECRA). Kahn will make his initial appearance in the Central District of California.

“As alleged, Kahn illegally sent specialized technology from the United States to a Russian semiconductor manufacturer with ties to multiple other sanctioned Russian entities and did so by circumventing U.S. export laws and regulations”

U.S. Attorney Breon Peace for the Eastern District of New York

According to court documents, Kahn is the owner of Senesys Incorporated, which is based in California, and Sensor Design Association, which maintains a contact address in Brooklyn. As alleged in the complaint and other public filings, Kahn operated these two businesses – ostensibly involved in “security software development” and the testing of silicon wafers for military avionics and space users – through which he engaged in a years-long conspiracy to acquire and export sensitive and sophisticated electronics from the United States to a sanctioned Russian business without acquiring the appropriate licenses.

The Russian business, Joint Stock Company Research and Development Center ELVEES (Elvees) was added to the Commerce’s Department’s Entity List in March 2022 and was sanctioned by the Treasury Department in September 2022 because of its critical role in facilitating Russia’s military and its invasion of Ukraine.

For example, according to the complaint, in 2022, Kahn exported U.S.-origin network interface controllers and a radio-frequency transmitter to Elvees in Russia by way of a Hong Kong-based shipping company. This item required an export license from the Commerce Department, which Kahn did not obtain.

If convicted, Kahn faces a maximum penalty of 20 years in prison for conspiracy to violate the ECRA.

“Price Cap” violator was found in The United Arab Emirates

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has taken its first oil price cap enforcement action of 2024, targeting a shipping company linked to a price cap violation.

“Today’s actions once again demonstrate that anyone who violates the price cap will face the consequences”

Deputy Secretary of the Treasury Wally Adeyemo

United Arab Emirates-based shipping company Hennesea Holdings Limited (Hennesea) is the ultimate owner of 18 vessels, including the HS Atlantica, which

OFAC previously identified as having engaged in the transport of crude oil of Russian Federation origin priced above the $60 per barrel price cap while using a covered U.S.-based provider after the price cap policy came into effect.

On December 1, 2023, OFAC identified the HS Atlantica as property in which Hennesea’s subsidiary, U.S.-designated HS Atlantica Limited, has an interest. Today, OFAC is additionally re-identifying the HS Atlantica as property in which Hennesea has an interest.

Shortly before the price cap went into effect, Hennesea, which was established in late 2022, acquired older tankers that ship Russian crude oil and petroleum products. Tankers ultimately owned by Hennesea have repeatedly conducted port calls in Russian Federation ports.

OFAC identified the following vessels, all of which are beneficially owned by Hennesea, as property in which Hennesea has an interest:

  • ARISTO (IMO 9327413)
  • HAI II (IMO 9259599)
  • HS ARGE (IMO 9299745)
  • HS ATLANTICA (IMO 9322839)
  • HS BURAQ (IMO 9381732)
  • HS ESBERG (IMO 9410894)
  • HS EVERETT (IMO 9410870)
  • HS GLORY (IMO 9249087)
  • HS LEGEND (IMO 9381744)
  • HS STAR (IMO 9274446)
  • LA PRIDE(IMO 9274616)
  • MONA (IMO 9314818)
  • NELLIS (IMO 9322267)
  • OSPEROUS (IMO 9412995)
  • PERIA (IMO 9322827)
  • SARA II (IMO 9301615)
  • SENSUS (IMO 9296585)
  • UZE (IMO 9323338)

The United States is part of an international coalition of countries, including the G7, the European Union, and Australia, that have committed to prohibit the import of crude oil and petroleum products of Russian Federation origin. These countries, home to many best-in-class financial and professional services, have also committed to restrict a broad range of services related to the maritime transport of crude oil and petroleum products of Russian Federation origin (“Russian oil”) – unless that Russian oil is bought and sold at or below the specific price caps established by the Coalition or is authorized by a license. This policy is known as the “price cap.”

Guatemalan former president and his children barred from entering US

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The State Department has banned Alejandro Eduardo Giammattei Falla, former president of Guatemala, as generally ineligible for entry into the United States due to his involvement in significant corruption.

The Department is also designating his adult daughter, Ana Marcela Dinorah Giammattei Caceres, his adult son, Alejandro Eduardo Giammattei Caceres, and his adult son, Stefano Giammattei Caceres, as generally ineligible for entry into the United States, in accordance with U.S. law.

The State Department has credible information indicating that Giammattei accepted bribes in exchange for the performance of his public functions during his tenure as president of Guatemala, actions that undermined the rule of law and government transparency.

Over the past three years, US goverment has taken steps to impose visa restrictions or sanctions on nearly 400 individuals, including public officials, private sector representatives, and their family members for engaging in corrupt activities or undermining democracy or the rule of law in Guatemala.

Giammattei became the presidential candidate for the Vamos party in the 2019 presidential elections. He placed second in the first round behind Sandra Torres on 16 June 2019, with 13.95% of the vote, but won the second round against the latter on 11 August 2019, with 57.96% of the vote.

On 14 January 2020, Giammattei assumed office as president of the Republic of Guatemala.

The South Korean goverment has sanctioned oil tankers

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South Korea has imposed its own independent sanctions on ships for the first time since 2016. Two individuals and three organizations that supported North Korea’s nuclear and missile development, engaged in sea transshipment, import and smuggling of oil to North Korea, were also sanctioned.

The Ministry of Foreign Affairs said in a statement that North Korea had imported 780,000 barrels of refined oil by April 2023, 1.5 times the annual limit.

Ten of the eleven vessels sanctioned are oil tankers, built mainly in the 80s of the last century.

Sanctions have been imposed on the following vessels:

  • NAM DAE BONG (IMO 9132612) – Oil Products Tanker
  • NEW KONK (IMO 9036387) – Oil Products Tanker
  • UNICA (IMO 8514306) – Oil Products Tanker
  • XING MING YANG 888 (IMO 8410847) – Oil Products Tanker
  • UBBLIC (IMO 8126082) – Oil Products Tanker
  • A BONG 1 (IMO 8669589) – Oil Products Tanker
  • KYONG SONG 3 (IMO 8356584) – a General Cargo Ship
  • LITON (IMO 8346395) – Oil Products Tanker
  • A SA BONG (IMO 9054896) – Oil Products Tanker
  • GOLD STAR (IMO 9146247) – Oil Products Tanker
  • ATHENA (IMO 9063811) – Oil Products Tanker

The Government of the Republic of Uzbekistan will sell the football club to those who are not included in the sanctions lists

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The Government of the Republic of Uzbekistan has decided to sell the Pakhtakor football club, which was helped by Russian billionaire Alisher Usmanov, who is under sanctions from the United States, the European Union and the United Kingdom.

100% of the state share in Pakhtakor Football Club LLC has been put up for sale. The explanation for the auction states that none of the applicants for the purchase of the club and related persons should be on the sanctions lists of the European Union and the United States, and also have a low probability of being included in such lists in the future.

The Pakhtakor Club was founded in 1956. In 2018, the media reported that businessman Alisher Usmanov would provide the club with “financial assistance” in the amount of $100 million.

The initial bidding price is still unknown.

The European Union imposes sanctions on Hamas and Al-Shabab leaders

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The Council of the EU decided to add one individual to the EU terrorist list. This decision comes as part of European Union’s response to the threat posed by Hamas and its brutal and indiscriminate terrorist attacks in Israel on 7 October 2023.

The individual designated today is Yahia Sinouar, the political leader of Hamas. Following his listing, Yahia Sinouar is subject to the freezing of his funds and other financial assets in EU member states. It is also prohibited for EU operators to make funds and economic resources available to him.

Furthermore, the Council has added one individual to the list of those subject to restrictive measures against ISIL (Da’esh) and Al-Qaeda and persons, groups, undertakings and entities associated with them.

The measures target Ahmed Khaled Müller, a member of Al-Shabab in Somalia. The sanctioned individual has participated in combat operations and committed terrorist acts on behalf of Al-Shabab. The latter operates in the Horn of Africa region, is responsible for numerous terrorist acts in Kenya, Somalia, as well as neighbouring countries, and is affiliated with Al-Qaida.

With this new listing and the de-listing of a deceased individual today, a total of 15 persons are subject to a travel ban and an asset freeze, and five groups to an asset freeze. In addition, EU persons and operators are forbidden from making funds or economic resources available to the listed persons and groups.

The Swiss goverment wants to strengthen sanctions against Russia

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The Swiss goverment wants to strengthen sanctions against Russia and control over the implementation of restrictive measures against the Russian Federation. The relevant report is published on the official website of the Swiss Government.

“The Federal Council is also considering other possibilities to strengthen the existing sanctions regime, for example, by tightening the criminal provisions in the law on the application of sanctions based on the law on property control or the law on military property,” the Goverment said.

On 21 December, 2023 the Federal Department of Economic Affairs, Education and Research (EAER) further expanded its sanctions listings against Russia. This brought Switzerland in line with the additional sanctions listings decided by the EU.

As part of a 12th package of sanctions adopted on 18 December, the EU imposed new measures against Russia. In turn, on 21 December the EAER imposed sanctions within its jurisdiction on a further 61 individuals and 86 entities.

Among the newly sanctioned individuals were members of the Belarusian armed forces, leaders of companies supporting Russia’s military and industrial capabilities, and members of the Central Election Commission of the Russian Federation.