Sanctions Top-5 for the week ending 14 January 2022

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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This week’s briefing covers the weeks ending 14 and 7 January 2022

  1. The US State Department named one Russia-based North Korean national, a Russian national, and a Russian entity as Specially Designated Nationals (SDNs) under Executive Order 13382 for procuring items for use in North Korea’s weapons of mass destruction program. Meanwhile, the US Office of Foreign Assets Control (OFAC) named five North Korean individuals located in Russia and China as SDNs for their ties to North Korea’s Second Academy of Natural Sciences (SANS). The actions were a response to North Korea’s latest round of ballistic missile tests last week.


The ECOWAS Mali-related sanctions look tough on paper and have the potential to up the cost on the Malian government’s decision to delay post-coup elections originally planned for February 2022. The six-point package includes a recall of ambassadors, border closures, a partial trade embargo, asset freezes targeting the Republic of Mali, state-owned companies, and parastatals, and restrictions on multilateral development bank financing. (ECOWAS lifted an earlier sanctions package after the adoption of Mali’s Transition Charter in October 2020.) As to the trade and financial sanctions, the practical question is whether ECOWAS member states and their private sectors are prepared to administer and enforce the sanctions to achieve their political impact. I think it’s also worth noting how the ECOWAS response differs from ASEAN’s response to the February 2021 military coup in Myanmar.

OFAC’s trading company settlement highlights a big challenge for compliance officers: how to identify “rogue” employees who circumvent the company’s sanctions policies. (In 2019, OFAC designated one such employee as a Foreign Sanctions Evader after penalizing a company for violating the ITSR.) OFAC’s latest settlement notice recommends that companies implement risk-based controls, including testing and auditing, and exercise oversight of foreign subsidiaries. To that I would add whistle blower hotlines and lots of good training.

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(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

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