Sanctions Top-5 for the week ending 16 April 2021

  1. The Biden administration unveiled a package of Russia-related sanctions in response to the recent SolarWinds hack, US election interference, Crimea, and other “harmful foreign activities.” The measures include a new Executive Order 14024 authorizing blocking sanctions on a wide range of Russian targets, Directive 1 imposing new restrictions on Russian government debt, and sanctions on dozens of individuals and entities named as Specially Designated Nationals (SDNs). Russia announced countermeasures. (More on this below.)
  2. The US Office of Foreign Assets Control (OFAC) published updates to four FAQs to reflect the termination of most Sudan-related US sanctions since 2017. Importantly, FAQ 500 states that “no license from OFAC is required to export or reexport agricultural commodities, medicines, or medical devices to Sudan,” as of 14 December 2020. FAQ 836 summarizes OFAC’s (few) remaining Sudan-related sanctions.
  3. The European Council added eight individuals and three entities to the EU Sanctions List in response to violence against demonstrators in late 2019. The targets include Hossein Salami, the head of Iran’s Islamic Revolutionary Guard Corps.
  4. OFAC named a regional commander of the Mexico-based Cartel de Jalisco Nueva Generacion as a significant foreign narcotics trafficker (SFNK) under the Foreign Narcotics Kingpin Designation Act. Meanwhile, the US State Department announced a USD 5 million reward for information leading to his arrest or conviction.
  5. The US Commerce Department reported that it had issued a subpoena to an unnamed Chinese company “to support the review of transactions pursuant to Executive Order 13873” concerning information and communications technology and services. In March 2020, the Commerce Department announced subpoenas involving multiple Chinese companies operating in the United States.




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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: