Latin America flies under the sanctions radar, but this region is more sanctioned by the world than North Korea or Iran. As of October 2021, 1990 sanctions have been imposed against designees in Latin America, with 95% of them imposed by the United States.

In the last two years, OFAC has issued ten sanctions advisories, whereas in the eight preceding years, it issued nine advisories. OFAC under the Biden Administration has maintained the tempo set in the Trump Administration’s last year, issuing four advisories in its first year alone. See all of the topics of sanctions advisories here.

Commerce announced that it will add four major cyber actors under its export controls list. Amongst those targeted is Israel’s NSO Group, which is responsible for creating and exporting the Pegasus military-grade spyware that has been used to spy on journalists, activists, and heads of governments from around the world. Commerce will also be designating Candiru, another Israel-based cyber firm; Positive Technologies, a Russia-based computer that was involved in the SolarWinds hack; and Computer Security Initiative Consultancy PTE. LTD, a Singapore-based cybersecurity consulting firm. The designation of the two Israeli entities signals that the United States will begin taking cyber offenses much more seriously, even if it disrupts its strategic security partnership with the Israeli government. 

In October 2021, the US Treasury's sanctions authority, the Office of Foreign Assets Control (OFAC), issued sanctions compliance guidance for the cryptocurrency industry. Castellum.AI has helped its users meet or exceed the specific steps mentioned in the guidance document recommendations since January 2021.

The DDTC runs two main lists: Statutory Debarment and Administrative Debarment. While a designation on either list will result in an individual being prohibited from participating directly or indirectly in any activities that are subject to the International Traffic in Arms Regulations (ITAR), there are substantial legal differences between the two lists. For example, a designation under the Statutory Debarment is made “solely upon the outcome of a criminal proceeding,” whereas the Assistant Secretary of State for Political-Military Affairs may debar and prohibit any individual under DDTC’s Administrative Debarment for any of the reasons outlined in the ITAR.

Export controls are laws that regulate and restrict the release of critical technologies, information, and services to foreign nationals. Over 50 countries globally, from Argentina to Ukraine, have sophisticated export control regimes that focus on goods, technologies and locations. For example, carbon fiber from the United Kingdom cannot be exported to North Korea. But only the US and Japan have export watchlists that name individuals and entities, in addition to goods. Japan’s export control list, however, is very much driven by US listings, with over 65% overlap with US sanctions and export control lists; it also changes infrequently. For this reason, our export control tracker will initially focus only on US export control lists.

With the Taliban’s takeover of Afghanistan, we reviewed who in the Taliban leadership is under sanctions, and found that despite being the leader of an insurgency that has killed over two thousand US soldiers, the current leader of the Taliban is not sanctioned by the United States. Even more strange, Russia has imposed more sanctions against current Taliban leadership than the United States.

On Friday the EU announced that it will implement Lebanon-focused sanctions. The new legal authority, with no one yet named under it, will focus on those that: Obstruct or undermine the democratic political process; Obstruct or undermine [...] accountability and good governance in the public sector or the implementation of critical economic reforms; Engage in serious financial misconduct concerning public funds.

Castellum.AI has developed a methodology to determine whether, and how, sanctions from particular countries violate human rights, designating Russia, Pakistan, and Turkey in that order as the biggest violators. Castellum.AI’s methodology relies on how sanctions of different countries hold up with a number of criteria, the four most important being: clear standards for designations; provisions of evidence for designations; whether or not clear legal pathways exist to challenge designations; and whether procedures exist for unblocking incorrectly frozen funds.

In the changeover from CCMC to CMIC lists, the highlights are the following: The NS-CCMC list had 39 designees before termination. The NS-CMIC list has 59 designees as of June 3rd. In the switch over between lists: 10 designees were removed, 29 designees were migrated from NS-CMCC, 30 designees were added.