Sanctions Top-5 for the week ending 1 January 2021

  1. The US Office of Foreign Assets Control (OFAC) released a set of somewhat helpful FAQs about Executive Order 13959, which prohibits US persons from purchasing securities of so-called “Communist Chinese military companies” (CCMC) beginning 11 January 2021. OFAC also introduced the Non-SDN Communist Chinese Military Companies List with identifying information on the companies. (Another list!)
  2. OFAC announced a USD 653,347 settlement with a Saudi Arabia-based bank for 13 violations of OFAC’s Syria and Sudan sanctions programs. According to the OFAC settlement notice, the bank processed transactions through the US financial system related to activities or persons in Syria and Sudan. (At the time, Sudan was still subject to comprehensive US sanctions.)
  3. OFAC announced a USD 98,830 settlement with a California-based digital assets company for more than 180 violations of OFAC’s Crimea, Cuba, Iran, Sudan, and Syria sanctions programs. According to the OFAC settlement notice, the company failed to implement internet protocol (IP) blocking, allowing persons in sanctioned territories to access its services online.
  4. OFAC named a judge and a prosecutor in Venezuela as Specially Designated Nationals (SDNs) under Executive Order 13692 for their roles in the prosecution and imprisonment of six US nationals on charges of corruption. The individuals, who were executives at US-based Citgo, are also known as the “Citgo 6.”
  5. Congress voted to override Donald Trump’s veto on the National Defense Authorization Act (NDAA) for Fiscal Year 2021. The NDAA is an annual exercise and usually includes a sanction or two. This year’s sanctions provisions include expanded sanctions on supporters of the Nord Stream 2 and Turkstream pipeline projects, among others. (Full text available here.)




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Nicholas Turner

Nicholas Turner

US attorney in Hong Kong specializing in economic sanctions, financial crimes. Sign up for emails: LinkedIn at: