Sanctions Top-5 for the week ending 13 November 2020

  1. The White House issued an executive order that will prohibit US persons from purchasing securities of “Communist Chinese military companies” previously identified by the Department of Defense in June and August 2020. The prohibitions take effect on 11 January 2021. (More on this below.)
  2. The State Department announced sanctions against four additional PRC and Hong Kong government officials under Executive Order 13936 for their roles in implementing the Hong Kong National Security Law. While the four individuals are now Specially Designated Nationals (SDNs), they have not (yet) been added to the State Department’s report under Section 5(a) of the Hong Kong Autonomy Act (HKAA). This means non-US financial institutions are not exposed to secondary sanctions risk under the HKAA for knowingly conducting “significant transactions” with them.
  3. The US Office of Foreign Assets Control (OFAC) named four individuals and six companies in Iran, Taiwan, Hong Kong, and Brunei as SDNs under Executive Order 13382 (Weapons of Mass Destruction) for procuring items on behalf of an Iranian military firm. Separately, the US Department of Justice (DOJ) charged one of the individuals and two of the companies with conspiring to violate US sanctions on Iran. In related news, Axios reported the Trump administration is planning a “flood” of Iran-related sanctions between now and 20 January 2021.
  4. OFAC named seven individuals and ten entities in Syria and Lebanon as SDNs pursuant to the Caesar Syria Civilian Protection Act and several Syria-related executive orders for “attempting to revive Syria’s deteriorating petroleum industry.” Separately, the State Department named a pro-government Syrian militia and one of its commanders as SDNs under Executive Order 13894 for obstructing a ceasefire in Syria.
  5. Russia’s foreign minister told media that Russia would soon announce “mirror-like sanctions” against German and French officials in response to EU chemical-weapons sanctions on six Russian nationals and one entity in October 2020. As mentioned before, the EU sanctions followed a suspected nerve agent attack on opposition figure Alexei Navalny in August 2020.




Get the Medium app

A button that says 'Download on the App Store', and if clicked it will lead you to the iOS App store
A button that says 'Get it on, Google Play', and if clicked it will lead you to the Google Play store
Nicholas Turner

Nicholas Turner

US attorney in Hong Kong specializing in economic sanctions, financial crimes. Sign up for emails: LinkedIn at: