Sanctions Top-5 for the week ending 13 March 2020

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 US Office of Foreign Assets Control (OFAC) named a Switzerland-based Rosneft subsidiary, TNK Trading International SA, as a Specially Designated National (SDN) pursuant to Executive Order 13850 for operating in the oil sector of Venezuela. Last month, OFAC designated another Rosneft subsidiary, Rosneft Trading SA, also for its Venezuela oil activity.
  2. OFAC designated four companies under the Foreign Narcotics Kingpin Designation Act for their connections to two sanctioned Mexican drug cartels. The targets include a gas station and two restaurant management companies associated with a bakery and a sushi joint that OFAC sanctioned in September 2017.
  3. OFAC named the former commander of the Zimbabwean National Army’s Presidential Guard Brigade and Zimbabwe’s Minister of National Security as SDNs under Executive Order 13469 for their roles in human rights abuses against protesters and opposition figures. The US State Department previously issued visa bans against the men in August 2019 and October 2019, respectively. Meanwhile, OFAC lifted sanctions on four Zimbabwean politicians (three of whom are deceased).
  4. The European Union extended its sanctions against persons threatening the territorial integrity, sovereignty and independence of Ukraine for an additional six months, until 15 September 2020. In related news, on 6 March 2020, the European Union lifted sanctions against former Ukrainian Prime Minister Mykola Azarov and former Energy Minister Edward Stavytskyi, following various court challenges.
  5. A federal judge for the US District Court for the Southern District of Florida dismissed a complaint against an online retailer and a wholesaler under Title III of the Helms-Burton Act. The plaintiff alleged the defendants trafficked in property covered by Title III by selling Cuban-origin charcoal produced on a farm seized from the plaintiff’s grandfather by the Cuban government in 1964.


Is Switzerland Europe’s sanctions hot spot? Since last month, OFAC has designated two Switzerland-based oil trading companies (both Rosneft subsidiaries) in connection with Venezuela, announced a USD 7,829,640 settlement with a Swiss technology firm for violations of the Global Terrorism Sanctions Regulations, and unveiled the US-Swiss Humanitarian Trade Arrangement (SHTA) for payments related to exports of agricultural commodities, food, medicine, and medical devices to Iran. It’s a compliance fondue.

Bonus item: OFAC terminated its Terrorism Sanctions Regulations found at 31 CFR Part 595 following the adoption of Executive Order 13886 on 9 September 2019. The September 2019 order upgraded various terrorism-related US sanctions authorizations and terminated the national emergency in Executive Order 12947 of 23 January 1995, which provided the legal basis for Part 595. OFAC still has four other sets of terrorism-related regulations at 31 CFR Parts 566, 594, 596, and 597.

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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