Sanctions Top-5 for the week ending 1 October 2021

Here are five things that happened this week in the world of economic sanctions that I think you should know about.

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  1. The US Office of Foreign Assets Control (OFAC) announced a pair of settlements with two subsidiaries of a Texas-based oil services conglomerate for violations of OFAC’s Ukraine and (defunct) Sudan sanctions regulations. In both cases, US-based employees of the companies facilitated exports from outside the United States to prohibited destinations. (If I’m not mistaken, this is the first time OFAC has brought a public enforcement action under Directive 4 of the sectoral sanctions program.) The settlement notices are available here and here.


There’s a fine line between sharing information (which is OK under most OFAC regulations) and performing a service (which is not OK). That is the takeaway from the DOJ’s case against the US national who traveled to North Korea for the Pyongyang Blockchain and Cryptocurrency Conference in April 2019. (Can you imagine the schwag?) According to the DOJ, the presentation contributed to the North Korean government’s ability to overcome foreign sanctions by mining cryptocurrency. It probably didn’t help that the US Department of State specifically denied the individual’s request for authorization to travel to North Korea before the event.

Financial Secretary Paul Chan has been in the news a lot lately. He was among the local officials who spoke in favor of a local legislative process for incorporating the Anti-Foreign Sanctions Law into Hong Kong law. (The law does not currently apply in Hong Kong.) One could read his latest comments to suggest the proposal is not expected to move ahead anytime soon. I guess we’ll know when we know . . .

Did I miss something? Send me a message or comment on LinkedIn.

(The views expressed are my own and do not constitute legal advice. Photo from Vladislav Reshetnyak.)



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Nicholas Turner

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