Sanctions Top-5 for the week ending 11 February 2022

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 UK government adopted The Russia (Sanctions) (EU Exit) (Amendment) Regulations 2022 to expand the criteria for imposing asset freezes in relation to the situation in Ukraine. According to a statement from the UK Foreign Secretary, “[t]he UK and its partners will not hesitate to act” in response to further Russian “aggression towards Ukraine.” (For more on this, see my colleague Alex Melia’s blog post here.)
  2. Meanwhile, Ukraine’s National Security and Defense Council adopted sanctions against a television station linked to former Ukrainian lawmaker Yevhen Murayev. Last month, the UK government announced it had uncovered a plot to replace Ukraine’s leadership, with Murayev “being considered as a potential candidate” to lead a pro-Russia government.
  3. President Biden signed an executive order blocking approximately USD 7 billion in funds of Da Afghanistan Bank (DAB), Afghanistan’s central bank, held in the United States. According to the White House, half of the funds will be used “for the benefit of the Afghan people,” and half will be made available to settle claims against the Taliban of US victims of terrorism.
  4. The US Commerce Department’s Bureau of Industry and Security (BIS) caused a stir by adding 33 Chinese companies to the little known and not well understood Unverified List (UVL) under the Export Administration Regulations (EAR). (More on this below.)
  5. OFAC named an individual in Ecuador and an individual in Mexico as Specially Designated Nationals (SDNs) under recently adopted Executive Order 14059. According to a Treasury Department news release, the individuals are linked to the Cartel de Jalisco Nueva Generacion (CJNG) and the Sinaloa Cartel and are responsible for trafficking significant amounts of cocaine from Ecuador to the United States.


Commerce Department lists are kind of like meteorites. Most of us are oblivious to them until they come crashing down on something. It wasn’t long ago that people learned what the Entity List was for the first time. Now there’s the Unverified List. The good news is that the Unverified List is not the dinosaur killer the Entity List is made out to be. In most cases, companies wind up there because BIS wasn’t able to do a routine end-use check (the export control equivalent of a house call). It’s easy enough to fix in theory, and the companies aren’t accused of wrongdoing. In the meantime, exporters have a few extra steps to follow if their products are subject to the EAR.

One interesting trend lately is the use of sanctions to call out an opponent’s propaganda. Ukraine just did it. Last month, OFAC sanctioned another Ukrainian for using media to push a pro-Russia message. A week earlier it was a Nicaraguan government troll farm. The week before that, a politician in the Balkans who uses a media outlet to “advance his own personal and political goals.” Heck, there’s a whole OFAC program based on foreign interference in US elections. Welcome to the information age!

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.)




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

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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:

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