Sanctions Top-5 for the week ending 17 December 2021

  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.”




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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: