Sanctions Top-5 for the week ending 19 March 2021

Here are five things that happened this week in the world of economic sanctions that I think you should know about.

Sign up here if you would like to receive these summaries by email. Click here for an index of past Sanctions Top-5 briefings.

  1. The US State Department published an update to its October 2020 report under Section 5(a) of the Hong Kong Autonomy Act (HKAA), identifying an additional 24 PRC and Hong Kong officials. (The October 2020 report identified 10 officials.) Under Section 5(b) of the HKAA, the US Treasury Department has 30 to 60 days to identify any foreign financial institution that knowingly engages in a “significant transaction” with one of the 24 individuals. (More on this below.)


The big news overnight: the adoption of coordinated Xinjiang-related sanctions by Canada, the EU, the UK, and the United States. The PRC Ministry of Foreign Affairs responded by announcing sanctions on ten EU individuals and four entities. More on this next week.

What’s important about the State Department’s Section 5(a) update? The individuals were previously sanctioned under Executive Order 13936 in November and December 2020 and January 2021. That means banks would have identified them months ago. By all accounts, the report was intended to send a message before the US-PRC summit in Alaska that the Biden administration means business. (Sent. And. Received.) What matters now is OFAC’s forthcoming Section 5(b) report in about 30 to 60 days. Recall that OFAC issued a null report the first time around. Get ready for round two.

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.)



Get the Medium app

A button that says 'Download on the App Store', and if clicked it will lead you to the iOS App store
A button that says 'Get it on, Google Play', and if clicked it will lead you to the Google Play store
Nicholas Turner

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