By Melissa Miller Proctor
Yesterday, President Obama issued an Executive order entitled “Termination of Emergency with Respect to the Situation in or in Relation to Côte d’Ivoire” which lifts all U.S. sanctions against Côte d’Ivoire (Ivory Coast). These sanctions have been terminated and are no longer in effect, as of 8:00am ET on September 14, 2016. The Obama Administration’s decision to lift the sanctions on Côte d’Ivoire stems from the U.N. Security Council Resolution 2283, which terminated the arms embargo and travel and financial sanctions on Côte d’Ivoire in April 2016. OFAC has also removed the individuals who were targeted under the previous U.S. sanctions on the Côte d’Ivoire from the Specially Designated Nationals Lists (SDN Lists). OFAC will be removing the Côte d’Ivoire Sanctions Regulations (in 31 CFR Part 543) from the Foreign Assets Control Regulations in the near future.
However, U.S. companies should continue to screen their international transactions against the various U.S. restricted parties lists (including OFAC’s SDN Lists), even those transactions in or with Côte d’Ivoire, because there may be individuals and entities in that country that are subject to other U.S. economic sanctions programs separate and apart from the former sanctions on Côte d’Ivoire. For example, Ali Ahmad Chehade of Côte d’Ivoire is still listed on the SDN Lists because he is a target of the U.S. Specially Designated Global Terrorist (SDGT) sanctions and the Hizballah Financial Sanctions Regulations—programs that were not related to the former sanctions on Côte d’Ivoire.