Sanctions Top-5 for the week ending 17 July 2020

  1. Donald Trump signed the Hong Kong Autonomy Act (HKAA) into law. At the same time, he issued Executive Order 13936 which: (i) directs US agencies to take steps to revoke Hong Kong’s differential treatment from mainland China under US laws per the Hong Kong Policy Act of 1992; and (ii) authorizes blocking sanctions (i.e. asset freezes) under the International Emergency Economic Powers Act (IEEPA) on individuals and entities in relation to Hong Kong. (More on this below.) (To read more about Executive Order 13936, see my team’s client alert here.)
  2. The US Office of Foreign Assets Control (OFAC) announced a USD $665,112 settlement with a UAE-based cigarette filter maker for violations of the North Korea Sanctions Regulations. According to the OFAC settlement notice, the company exported products to North Korea using front companies and accepted payment into its account at a foreign branch of a US financial institution. The settlement was accompanied by a three-year Deferred Prosecution Agreement (DPA) with the US Department of Justice (DOJ).
  3. OFAC named three individuals and five entities located in Hong Kong, Russia, Sudan, and Thailand as Specially Designated Nationals (SDNs) under the Ukraine-/Russia-related, Cyber-related, and Election Interference programs for their connections to Yevgeniy Prigozhin, a Russian financier (known as “Putin’s chef”) sanctioned by OFAC in September 2019, March 2018, and December 2016.
  4. The US State Department updated its public guidance on Section 232 of the Countering America’s Adversaries Through Sanctions Act (CAATSA) to state that secondary sanctions could apply to investments and loans related to “Russian energy export pipelines such as Nord Stream 2 and the second line of TurkStream” after 15 July 2020.
  5. OFAC named four individuals in China and one entity in the British Virgin Islands as SDNs under the Foreign Narcotics Kingpin Designation Act for their connections to a synthetic opioid trafficking network sanctioned by OFAC in August 2019.

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