Sanctions Top-5 for the week ending 12 February 2021

  1. The first new sanctions program of the Biden era is here, and it’s Myanmar. The White House issued Executive Order 14014 authorizing sanctions on a wide range of targets in response to the military coup on 1 February 2021. The US Office of Foreign Assets Control (OFAC) named ten individuals and three entities as Specially Designated Nationals (SDNs) under the order, while the Bureau of Industry and Security (BIS) announced new licensing requirements for some exports to Myanmar. (For more information, read my team’s blog post here.)
  2. The US State Department announced the revocation of the designation of Ansar Allah (a.k.a. the Houthi movement) as a Specially Designated Global Terrorist (SDGT) under Executive Order 13224, in light of humanitarian concerns in Yemen. As previously reported, the outgoing Trump administration designated the group and three of its leaders as SDGTs in January 2021. The leaders are still sanctioned.
  3. OFAC issued General License №30A to authorize US persons to pay fees to Venezuela’s major port operator, Instituto Nacional de los Espacios Acuaticos (INEA). OFAC named INEA as an SDN on 19 January 2021, triggering concerns about humanitarian and other imports into the country. In related news, the US Government Accountability Office (GAO) issued a report on the humanitarian impacts of US sanctions on Venezuela since 2015.
  4. The Biden administration filed motions (here and here) asking two US federal courts to pause litigation over Trump-era rules to restrict certain transactions related to WeChat and TikTok. According to the filings, “the Department of Commerce has begun a review of certain recently issued agency actions” and “plans to conduct an evaluation of the underlying record justifying those prohibitions.” Meanwhile, efforts to force ByteDance Inc. to sell its TikTok app to Oracle and Walmart have been put on hold, according to reports.
  5. More EU sanctions on Russia coming? EU Minister for Foreign Affairs Josep Borrell said in a speech he would “put forward concrete proposals in response to the jailing of opposition figure Alexei Navalny. Meanwhile, Russian Foreign Minister Sergei Lavrov suggested in an interview that new sanctions could lead to a break in EU-Russia diplomatic relations. (Borrell’s comments follow a widely panned visit to Moscow earlier this month.)




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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: