[co-author: Jeremie Charles - Senior Associate, Eleni Theodoropoulou - Trainee]
On 22 January 2018, the Council of the EU adopted two Implementing Regulations related to the EU restrictive measures targeting designated persons in Venezuela and the Democratic People's Republic of Korea ("DPRK").
First, Implementing Regulation (EU) 2018/88 introduces asset-freezing measures on 7 individuals pursuant to Regulation (EU) 2017/2063 concerning restrictive measures against Venezuela. These individuals hold official positions and are deemed to be involved in the violation of democratic principles, the rule of law and/or human rights. They include:
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1. |
Néstor Luis Reverol Torres, Minister for Interior, Justice and Peace. |
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2. |
Gustavo Enrique González López, Head of the Bolivarian National Intelligence Service (SEBIN). |
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3. |
Tibisay Lucena Ramírez, President of the National Electoral Council (Consejo Nacional Electoral – CNE). |
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4. |
Antonio José Benavides Torres, Chief of the Capital District (Distrito Capital) Government. |
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5. |
Maikel José Moreno Pérez, President, and former Vice President, of the Supreme Court of Justice of Venezuela (Tribunal Supremo de Justicia). |
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6. |
Tarek William Saab Halabi, Venezuelan Attorney General appointed by the Constituent Assembly. |
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7. |
Diosdado Cabello Rondón, Member of the Constituent Assembly and First Vice President of the United Socialist Party of Venezuela (PSUV). |
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The EU sanctions on Venezuela were initially adopted on 13 November 2017 and aim to foster democratic solutions towards political stability in the country through a ban on arms and equipment for internal repression as well as asset-freezing measures. The EU designations follow US sanctions already in place since August 2017, all but one of the listed individuals (i.e., Diosdado Cabello Rondón) being also covered under US sanctions (see alert from 27 July 2017 here). However, unlike the US in Executive Order no. 13808, the EU has not targeted the Government of Venezuela or restricted Petróleos de Venezuela's ability to raise capital in EU markets.
Second, Implementing Regulation (EU) 2018/87 adds 17 individuals to the list of designated persons/entities subject to asset-freezing measures pursuant to Regulation (EU) 2017/1509 concerning restrictive measures against the DPRK. These individuals, all DPRK nationals, have been identified due to their involvement in illegal trade activities as well as activities aimed at facilitating the circumvention of the relevant UN sanctions. They include:
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1. |
CHOE Chan Il, Director of the Dandong office of Korea Heungjin Trading Company (a UN designated entity). |
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2. |
KIM Chol Nam, Director of the Dandong branch of Sobaeksu United Corp (an EU designated entity). |
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3. |
JON Chol Young, Representative in Angola of Green Pine Associated Corporation (a UN designated entity) and DPRK diplomat in Angola. |
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4. |
AN Jong Hyuk, Representative of Saeng Pil Trading Corporation (an alias of Green Pine Associated Corporation) and DPRK diplomat in Egypt. |
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5. |
CHOL Yun, Contact person of the DPRK Company General Precious Metal (an alias of Green Pine Associated Corporation) and DPRK diplomat in China. |
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6. |
CHOE Kwang Hyok, Representative of Green Pine Associated Corporation. |
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7. |
KIM Chang Hyok, Representative in Malaysia of Pan Systems Pyongyang (an EU designated entity). |
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8. |
PARK Young Han, Director of Beijing New Technology (identified as a front company of UN designated entity KOMID). |
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9. |
RYANG Su Nyo, Director of Pan Systems Pyongyang. |
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10. |
PYON Won Gun, Director of Glocom (front company of Pan Systems Pyongyang). |
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11. |
PAE Won Chol, Operator of Pan Systems Pyongyang. |
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12. |
RI Sin Song, Operator of Pan Systems Pyongyang. |
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13. |
KIM Sung Su, Representative in China of Pan Systems Pyongyang. |
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14. |
KIM Pyong Chol, Operator of Pan Systems Pyongyang. |
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15. |
CHOE Kwang Su, Representative of Haegeumgang Trading Company and DPRK diplomat in South Africa. |
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16. |
PAK In Su, involved in activities related to the illegal sale of coal from DPRK in Malaysia. |
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17. |
SON Young-Nam, DPRK diplomat in Bangladesh. |
The EU sanctions on the DPRK have been in place since 27 March 2007 (and consolidated in Regulation (EU) 2017/1509) to counter the DPRK's accelerated nuclear and ballistic programmes conducted in disregard of UN Security Council resolutions. The newly adopted EU Regulation largely follows UN measures imposed through UN Security Council resolutions. The total number of EU designations now amounts to 58 individuals and 10 entities.
