Sanctions Top-5 for the week ending 15 October 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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This week’s briefing covers the weeks ending 8 and 15 October 2021.

  1. The US Office of Foreign Assets Control (OFAC) published a guidance document on sanctions compliance aimed at the virtual currency industry. The document looks like a sequel to OFAC’s 2019 “A Framework for OFAC Compliance Commitments” and offers a useful primer for anyone who needs a refresher on sanctions best practices. Meanwhile, the US Treasury Department’s Financial Crimes Enforcement Network (FinCEN) published a report on ransomware trends in suspicious activity reports (SARs) filed under the Bank Secrecy Act between January and June 2021.


OFAC is putting a lot of effort these days into encouraging virtual currency firms to take sanctions compliance seriously. As mentioned, OFAC issued an updated ransomware guidance and sanctioned a Russian cryptocurrency exchange last month. In December 2020 and February 2021, the agency brought enforcement actions against two US-based exchanges for providing services to users in comprehensively sanctioned territories (info here and here). The new guidance document (in futuristic purple and teal) does not impose any new regulatory obligations on its own. But it does provide a handy benchmark to help banks and others assess the adequacy of their counterparties’ compliance programs. (For more on the new advisory, see my team’s blog post here.)

As to that FinCEN report, the most interesting detail could be how few SARs are being filed in relation to ransomware. According to the report, there were 635 ransomware SARs filed between 1 January and 30 June 2021. For comparison, FinCEN received more than 2.5 million SARs in total last year.

In case you missed it: Bernard Chan, a non-official member of the Hong Kong Executive Council, told Bloomberg that he is “pretty sure” Hong Kong will get an Anti-Foreign Sanctions Law eventually.

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.)



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Nicholas Turner

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