By Maya Lester KC & Michael O’Kane

Sanctions Profile: Chemical Weapons

At a glance

The EU adopted Council Regulation (EU) 2018/1542 and Council Decision (CFSP) 2018/1544 in October 2018 to establish a new sanctions regime to address the use and proliferation of chemical weapons.

The UK adopted The Chemical Weapons (Sanctions) (EU Exit) Regulations 2019 in January 2021 to deter the proliferation and use of chemical weapons, and encourage the effective implementation of the Chemical Weapons Convention.

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British American Tobacco $508 million OFAC sanctions settlement

British American Tobacco p.l.c. (BAT) has agreed to pay $508,612,492 to settle potential civil liability for apparent violations of US sanctions on North Korea and WMD proliferators. It also agreed to significant compliance commitments and investments for the next 5 years. Settlement Agreement, Enforcement Release, Press Release and Notice. According to OFAC, in 2001, British-American Tobacco Marketing (Singapore) PTE Ltd …

North KoreaNorth Korea Chemical WeaponsChemical Weapons

OFAC lists Iranian UAV and weapons procurement network

In coordination with the FBI, OFAC has designated 4 Iranian and Turkish entities and 3 Iranian and Turkish nationals for their alleged involvement in the procurement of equipment, including European-origin UAV (drone) engines, in support of Iran’s UAV and weapons programs. The procurement network is said to operate on behalf of Iran’s Ministry of Defence and Armed Forces Logistics (MODAFL), …

IranIran Chemical WeaponsChemical Weapons

OFAC makes Iran-related designations

In separate actions last week, OFAC listed people and entities supporting the manufacture of Iranian drones and evading US sanctions on Iran. Drones OFAC designated a China-based network of 5 entities and 1 person said to be responsible for the sale and shipment of thousands of aerospace components, including components that can be used in Shahed-series UAVs, to the US-sanctioned …

IranIran Chemical WeaponsChemical Weapons

Recent US sanctions & de-listings

The US has made designations under its Iran and WMD sanctions regimes, and designations under, and de-listings from, its transnational criminal organisations sanctions regime. Iran On 9 February, OFAC listed 9 entities which are said to have played a critical role in the production, sale and shipment of hundreds of millions of dollars’ worth of Iranian petrochemicals and petroleum to …

IranIran Chemical WeaponsChemical Weapons

EU Russia & Iran & chemical weapons designations

The EU has made the following designations (press release & press release): 10 individuals and 1 entity linked to the poisoning of Alexei Navalny, and the production of chemical weapons delivery systems in Syria (Council Implementing Regulation (EU) 2022/2228 & Council Decision (CFSP) 2022/2232 ) 29 individuals and 3 entities relating to the death of Mahsa Amini and the violent response to the recent demonstrations in Iran (Council Implementing Regulations (EU) …

IranIran RussiaRussia Chemical WeaponsChemical Weapons

Current Sanctions



Council Regulation (EU) 2018/1542

Parent Regulation

Council Regulation (EU) 2018/1542

Amended by:

Council Implementing Regulation (EU) 2019/84

Council Implementing Regulation (EU) 2020/1463

Council Implementing Regulation (EU) 2022/1936


Council Decision (CFSP) 2018/1544

Parent Decision

Council Decision (CFSP) 2018/1544

Amended by:

Council Decision (CFSP) 2019/86

Council Decision (CFSP) 2019/1722

Council Decision (CFSP) 2020/1466

Council Decision (CFSP) 2021/1799

Council Decision (CFSP) 2022/1944

The Chemical Weapons (Sanctions) (EU Exit) Regulations 2019 (SI 2019/618)

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