Sanctions Top-5 for the week ending 17 December 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.


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.)



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: