Sanctions Top-5 for the week ending 17 September 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 White House issued a new Executive Order authorizing menu-based sanctions against persons within the Ethiopian government, the Eritrean government, the Tigray People’s Liberation Front, and the local government of Ethiopia’s Amhara region, in connection with the ongoing conflict and resulting humanitarian crisis in northern Ethiopia. The Office of Foreign Assets Control (OFAC) issued three general licenses and a series of FAQs related to the new order, although no one has been sanctioned under it yet. (More on this below.)
  2. OFAC designated a Colombian woman nicknamed La Patrona (the boss), her husband, her two sons, and two entities in Colombia as Specially Designated Nationals (SDNs) pursuant to the Foreign Narcotics Kingpin Designation Act. According to a Treasury Department news release, La Patrona leads an organization that profits from maritime shipments of drugs through northern Colombia.
  3. OFAC named 14 individuals and eight entities as SDNs under Executive Order 13224 for operating financial networks in support of Hizballah and Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF). According to a Treasury Department news release, the individuals sold gold and electronics and moved money through companies in China, Hong Kong, and elsewhere benefitting Hizballah and the IRGC-QF, which are also designated under Executive Order 13224.
  4. In related news, OFAC named five individuals in Turkey as SDNs under Executive Order 13224 for providing financial and other support to members of Al-Qa’ida.
  5. According to media reports, the Biden administration is preparing to unveil sanctions targeting cryptocurrency payments associated with ransomware. The sanctions could include SDN designations and guidance concerning ransomware risks.


Apparently, the White House hopes to avoid using the new Ethiopia-related sanctions by forcing the parties to open humanitarian channels and nudge them toward a ceasefire. The strategy is not unlike the EU’s recently adopted framework for Lebanon-related sanctions. Those haven’t been used (yet) but are meant to encourage “Lebanese leadership [to] put aside their differences and work together to form a government.” Query whether it’s possible to micromanage foreign crises through sanctions. In any event, OFAC’s new FAQs make clear, among other things, that the 50 Percent Rule would not apply to menu-based sanctions under the new Executive Order. Stay tuned for more.

I’m looking forward to talking sanctions with Aub Chapman and Cameron Mitchell at the upcoming “Navigating Sanctions Risk” webinar hosted by the Australasian chapter of the Association of Certified Anti-Money Laundering Specialists (ACAMS) this Thursday, 23 September, at 5:00 p.m. AEST. There’s more information at this link.

Happy Mid-Autumn Festival, 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

Nicholas Turner

US attorney in Hong Kong specializing in economic sanctions, financial crimes. Sign up for emails: LinkedIn at:

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