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.)
  2. OFAC named 14 individuals and 15 entities as SDNs pursuant to the Caesar Syria Civilian Protection Act of 2019 (the Caesar Act) and Executive Order 13894 for supporting luxury redevelopment projects in Syria and undermining peace efforts. The targets include Asma al-Assad, wife of Syrian President Bashar Al-Assad (who can forget her February 2011 profile in Vogue?). (Side note: Executive Order 13894 was adopted in response to Turkey’s military incursion into northeast Syria in October 2019.)
  3. The US Office of Foreign Assets Control (OFAC) named six individuals in Nigeria as Specially Designated Nationals (SDNs) pursuant to Executive Order 13694, as amended, for perpetrating online business and romance frauds. According to the Treasury Department news release, the targets pilfered more than USD 6 million from victims in the United States.
  4. OFAC named two companies in Mexico as SDNs pursuant to Executive Order 13850 for orchestrating the sale of Venezuelan-origin crude oil to buyers in Asia following the designation of two Rosneft subsidiaries earlier this year. OFAC also designated three individuals, six entities, and two vessels in Mexico, the United States, Singapore, the United Kingdom, and Greece, for taking part in the scheme.
  5. Singapore charged former commodities trader Tan Wee Beng and an accomplice with falsifying invoices to conceal North Korea-related transactions. As previously reported, in October 2019, Tan was indicted by the US Department of Justice (DOJ), added to the FBI’s Most Wanted List, and added to the SDN List for processing North Korea-related transactions through the US financial system.


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.)

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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