Sanctions Top-5 for the week ending 12 March 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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  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.


Talk about a David versus Goliath story. That is, if David were a USD 46 billion dollar technology company. The Xiaomi case is the latest example of a Trump-era restriction on a Chinese consumer company being held up by a federal court. Similar injunctions were issued in relation to WeChat and TikTok last year. Another company, Luokung Technology Corp. is also challenging its designation as a CCMC. As Wendy Wysong told the Financial Times: “The ruling in Xiaomi’s case will inspire other listed companies to ask the courts to review the grounds on which they have been placed on these lists.” (For more on the case, including a summary of the decision, check out my team’s blog post here.)

Need a data fix? Check out the monthly Global Sanctions Dashboard courtesy of the Atlantic Council’s GeoEconomics Center and Castellum.AI to see a comparison of recent sanctions listings and de-listings by country, topic, and other factors. Thanks to Peter Piatetsky for the link!

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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