Sanctions Top-5 for the week ending 12 March 2021

  1. A judge in the US District Court for the District of Columbia granted Xiaomi Corporation’s request for a preliminary injunction concerning the company’s designation as a so-called “Communist Chinese military company” (CCMC) by the US Department of Defense on 14 January 2020. Following the decision, the Office of Foreign Assets Control (OFAC) issued an FAQ confirming that restrictions under Executive Order 13959 on transactions in publicly traded securities of the company will not take effect, pending the outcome of the litigation. (Read the judge’s opinion here.)
  2. OFAC named two adult children of the commander-in-chief of Myanmar’s military and six of their companies as Specially Designated Nationals (SDNs) under Executive Order 14014. Their father was sanctioned by OFAC one month earlier, following the country’s military coup.
  3. OFAC revoked a controversial special license granted to billionaire Dan Gertler in January 2021. According to The New York Times, OFAC issued the license under pressure from senior officials during the waning days of the Trump administration.
  4. The State Department designated two Islamic State of Iraq and Syria (ISIS) affiliates in the Democratic Republic of the Congo and Mozambique as Foreign Terrorist Organizations and as Specially Designated Global Terrorists (SDGTs).
  5. The State Department announced visa bans against Ihor Kolomoyskyy, a former Ukrainian official accused of corruption, and his wife and kids under Section 7031(c) of the Department of State, Foreign Operations, and Related Programs Appropriations Act. The State Department also issued visa bans against two interrogators for Iran’s Islamic Revolutionary Guard Corps (IRGC) accused of human rights abuses against prisoners.




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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: