Sanctions Top-5 for the week ending 11 June 2021

  1. China unveiled its much anticipated Anti-Foreign Sanctions Law. (Google Translate for English.) See below for a few thoughts on the new law.
  2. President Biden issued an Executive Order revoking three prior orders that sought to impose restrictions on US persons transacting with WeChat, TikTok, and eight other Chinese mobile apps. Instead, the Commerce Department will study the threat posed by foreign apps and may take further action later. (For more, see my team’s blog post here.)
  3. The US Office of Foreign Assets Control (OFAC) removed several individuals and entities from the List of Specially Designated Nationals (SDNs) sanctioned under the Iran program. The move may have been intended to nudge Iran to come to an agreement for the United States to reenter the Joint Comprehensive Plan of Action (JCPOA), according to reports.
  4. OFAC named four individuals in Nicaragua as SDNs for their actions in support of President Daniel Ortega. The targets include the president of the country’s central bank, who is responsible for implementing a law “which could obligate Nicaraguan financial institutions to do business with designated persons in Nicaragua at the risk of facilitating sanctionable transactions.” (Sounds like an anti-foreign sanctions law to me.)
  5. The White House issued Executive Order 14033 updating the Western Balkans Sanctions program and authorizing SDN designations for persons engaged in significant corruption and actions that “destabilize the region by undermining democratic institutions and the rule of law or by violating human rights,” including in Albania. In May 2021, the State Department announced a visa ban against former Albanian President Sali Berisha based on allegations of significant corruption. (Earlier this month, the White House published a “Memorandum on Establishing the Fight against Corruption as a Core US National Interest.”)




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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: