Sanctions Top-5 for the week ending 10 December 2021

  1. The US Office of Foreign Assets Control (OFAC) marked International Anti-Corruption Day by naming seven individuals and eight entities in Angola, El Salvador, Guatemala, Liberia, South Sudan, and Ukraine as Specially Designated Nationals (SDNs) under the Global Magnitsky Sanctions program. Earlier in the week, OFAC sanctioned another 16 individuals and 24 entities in El Salvador and Kosovo linked to organized crime and corruption. OFAC also designated an individual in the Democratic Republic of the Congo and 12 related companies for providing material support to billionaire Dan Gertler, who is also sanctioned under the Global Magnitsky program. (For more on these developments, see my team’s blog post.)
  2. OFAC marked International Human Rights Day by naming 15 individuals and 10 entities in Bangladesh, China, Myanmar, and North Korea as SDNs under the Global Magnitsky Sanctions program. Earlier in the week, OFAC sanctioned 15 targets in Iran, Syria, and Uganda accused of repression and undermining democracy, ahead of the US government’s Summit for Democracy.
  3. OFAC added SenseTime Group Limited to the Non-SDN List of Chinese Military-Industrial Complex Companies (NS-CMIC List) under Executive Order 13959, ahead of the technology company’s (now postponed) initial public offering on the Hong Kong Stock Exchange. (More on this below.)
  4. OFAC issued a new General License №16 (GL-16) authorizing transactions related to non-commercial, personal remittances to Afghanistan that also involve the Taliban or the Haqqani Network that would otherwise be prohibited under OFAC’s terrorism-related sanctions regulations.
  5. OFAC announced a USD 133,860 settlement with an unnamed individual for violations of the Iranian Transactions Sanctions Regulations (ITSR). According to the OFAC settlement notice, the individual, who is in the United States, agreed to receive wire transfers on behalf of an Iranian company that was having trouble getting paid from a supplier in a third country.




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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: