Sanctions Top-5 for the week ending 10 September 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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This week’s briefing covers the weeks ending 3 and 10 September 2021.

  1. Reuters reported that the US Office of Foreign Assets Control (OFAC) issued a specific license authorizing the US government (and persons such as contractors acting on behalf of the US government) to engage in humanitarian transactions involving the Taliban in Afghanistan that would otherwise be prohibited under OFAC’s terrorism-related sanctions regulations. (More on this below.)


The OFAC specific license reported on by Reuters was issued to the State Department in late August and authorizes the US government and certain other persons to engage in “all transactions necessary and ordinarily incident to the provision of humanitarian assistance in Afghanistan that would otherwise be prohibited under” OFAC’s terrorism-related sanctions regulations through March 2022. For more on Taliban-related sanctions impacting Afghanistan, check out this “Sanctions Rapid Response Briefing Paper” by the one and only Justine Walker issued by the International Sanctions Compliance Task Force — Humanitarian Workstream of the Association of Certified Anti-Money Laundering Specialists (ACAMS).

For the export control wonks out there: here is Kevin Wolf’s must-read testimony to the US-China Economic and Security Review Commission with his take on the current direction of US export control policy. “[U]nilateral controls are quick and responsive, but are usually eventually counterproductive and ineffective. Multilateral controls under the current system are eventually effective,” but they require more work, Wolf stated. Hear, hear.

I’m looking forward to joining Rod Francis, Joanne Wong, and Edgar Ma for a panel on “Financial Crime Compliance⁠ — Managing Regulator Relationships” as part of FTI Consulting’s Continuing Professional Development Webinar Series, on Thursday, 16 September, at 4:30 to 5:30 p.m. Hong Kong time. Sign up here!

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: