Sanctions Top-5 for the week ending 17 December 2021

Nicholas Turner
3 min readDec 20, 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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  1. The US Office of Foreign Assets Control (OFAC) added eight companies to the Non-SDN List of Chinese Military-Industrial Complex Companies (NS-CMIC List) under Executive Order 13959. According to a Treasury Department news release, the US government believes the companies’ products “actively support the biometric surveillance and tracking of ethnic and religious minorities in China.” Meanwhile, the US Commerce Department’s Bureau of Industry and Security (BIS) added thirty-four entities in China to the Entity List under the Export Administration Regulations (EAR), including entities allegedly helping to develop “purported brain-control weaponry.” Spooky.
  2. The White House issued Executive Order 14059 to expand the criteria for designating foreign persons as Specially Designated Nationals (SDNs) who are determined to be involved in the global illicit drug trade. OFAC used the new Executive Order to name 10 individuals and 15 entities in Brazil, China, Colombia, and Mexico as SDNs, including several who were previously designated under Executive Order 13581 (Transnational Criminal Organizations) or the Foreign Narcotics Kingpin Designation Act. (For more on the new Executive Order, see my team’s blog post.)
  3. The US Congress passed the Uyghur Forced Labor Prevention Act. The Act, which the President intends to sign, will bar imports from China’s Xinjiang Province to the United States, unless the importer can overcome a presumption that the items were made using forced labor. (The text of the Act is available here.)
  4. The EU Council adopted restrictive measures against the Wagner Group, “a Russia-based unincorporated private military entity,” under the EU Libya, Syria, Ukraine, and human rights-related sanctions programs. According to an EU Council news release, the organization uses military contractors “to fuel violence, loot natural resources and intimidate civilians in violation of international law, including international human rights law.”
  5. Russia announced visa bans against seven unnamed UK individuals, who, according to Russia’s Foreign Ministry, “are closely involved in anti-Russian activities.” The countermeasures are a response to the UK’s August 2021 sanctioning of seven Russian operatives accused of being “directly responsible for the Novichok attack on Alexey Navalny.”


As mentioned last week, Executive Order 13959, as amended, prohibits US persons from purchasing or selling publicly traded securities of companies on the NS-CMIC List, as well as publicly traded securities that are derivative of, or designed to provide investment exposure to, such publicly traded securities. The restrictions apply only to companies whose names exactly match a name on the NS-CMIC List. OFAC’s 50 Percent Rule does not apply to the NS-CMIC List. The Entity List imposes a licensing restriction on the export, reexport, or in-country transfer of “items subject to the EAR” to persons on the Entity List.

Earlier today, OFAC updated the SDN List to note that five individuals previously sanctioned under the Hong Kong-related sanctions program are now subject to secondary sanctions risk under the Hong Kong Autonomy Act (HKAA). (The individuals were designated as SDNs in July 2021.) Several hours later, the US State Department issued an updated report under section 5(a) of the HKAA with the five names. (For a refresher on the HKAA, here is the Sanctions Top-5 for the week ending 16 October 2020.)

And a big congratulations to Elizabeth Rosenberg for being confirmed by the Senate over the weekend as the Treasury Department’s Assistant Secretary for Terrorist Financing!

Happy holidays, everyone!

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.)



Nicholas Turner

US attorney in Hong Kong specializing in economic sanctions, financial crimes. This is an archive of briefings published between 2017 and 2022.