Sanctions Top-5 for the week ending 19 June 2020

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. Donald Trump signed the Uyghur Human Rights Policy Act of 2020 into law. The Act, which was first introduced in early 2019, calls for asset freezes and visa bans against persons, including PRC officials, responsible for a litany of human rights abuses against minorities in the Xinjiang Uyghur Autonomous Region (XUAR). (Read the presidential signing statement here.)


Maybe it’s me, but the six email bandits sanctioned last week aren’t exactly what I picture when I think of a “significant threat to the national security, foreign policy, or economic health or financial stability of the United States” as described in Executive Order 13694. (If that’s the case, my spam box is full of potential SDNs.) Besides, this seems to be more of a law enforcement issue, rather than an OFAC one. Coincidentally, Mike Pompeo had a call on the same day with Nigerian Foreign Minister Geoffrey Onyeama, ostensibly about other things.

In case you missed it: the text of the proposed Hong Kong Autonomy Act finally made its way to The language matches a bootleg draft that had been floating around for a while. Observations: the Act does not call for asset freezes like last year’s Hong Kong Human Rights and Democracy Act, nor does it call for correspondent banking sanctions against foreign financial institutions. Instead, the Act spells out a menu of sanctions to be imposed in two phases, with conditions for lifting them. (There’s a lot more that can be said — drop me a line if you want to receive my separate Hong Kong-related updates.)

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.)



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Nicholas Turner

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