Below, we briefly summarize these recent developments.

EU adopts Moldova sanctions framework

On 28 April 2023, the EU established a new framework for targeted restrictive measures aimed at those responsible for, supporting or implementing actions that undermine or threaten the sovereignty of the Republic of Moldova, or its democracy, rule of law, stability or security through:

• obstructing or undermining the democratic political process, including by obstructing or seriously undermining the holding of elections or attempting to destabilise or overthrow the constitutional order;
• planning directing, engaging in, directly or indirectly, supporting or otherwise facilitating violent demonstrations or other acts of violence; or
• serious financial misconduct concerning public funds and the unauthorised export of capital.

The new framework allows for asset freeze measures to be imposed on listed persons and entities, as well as travel bans to be imposed on natural persons. As of yet, no persons or entities have been sanctioned under the new regime.

These measures come in the wake of increased and continued attempts to destabilize Moldova following Russia’s invasion of Ukraine, both from internal groups with vested interests and from Russia.

For more information, see a press release from the Council of the EU, Council Regulation (EU) 2023/888, and Council Decision 2023/891.

US expands the scope of sanctions on Sudan

On 4 May 2023, President Biden issued Executive Order 14098 Imposing Sanctions on Certain Persons Destabilizing Sudan and Undermining the Goal of a Democratic Transition.

The new executive order authorizes the imposition of blocking sanctions on persons identified to be responsible for, or complicit in, or to have directly or indirectly engaged or attempted to engage in:

• actions or policies that threaten the peace, security or stability of Sudan;
• actions or policies that undermine the formation or operation of a civilian transitional government, Sudan’s transition to democracy, or a future democratically elected government;
• actions or policies that undermine democratic processes or institutions in Sudan;
• censorship or other actions or policies that limit the exercise of freedoms of expression, association, or peaceful assembly;
• corruption;
• serious human rights abuse;
• the targeting of women, children, or any other civilians;
• the obstruction of the activities of United Nations missions;
• attacks against United Nations missions.

The new executive order, which expands the scope of the sanctions regime on Sudan established in 1997 by way of Executive Order 13067, addresses the situation in Sudan following the military’s seizure of power in October 2021 and the outbreak of inter-service fighting in April 2023.

As of yet, no persons or entities have been sanctioned under the new authority.

For more information, see a notice from OFAC, the updated OFAC FAQ # 836 and a statement from President Biden.

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WR Sanctions Alerts provide you with updates on material developments in the country-specific sanctions programmes implemented by the US, the UN, the UK, the EU and Norway. We will not provide updates on mere prolongations, without material changes, of existing sanctions programmes, nor on any listings or de-listings of individuals/entities placed on implemented sanctions lists. Please note that the WR Sanctions Alerts are provided as general information and do not constitute legal advice.