Sanctions Top-5 for the week ending 19 November 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 EU Council decided to amend the EU Belarus sanctions regime “to target individuals and entities organising or contributing to activities by the Lukashenko regime that facilitate illegal crossing of the EU’s external borders.” According to reports, the new (yet to be specified) sanctions will take effect at the end of November and will be coordinated with sanctions from the United States (expected in early December) and other nations.
  2. The US Office of Foreign Assets Control (OFAC) named the Ministerio Publico de Nicaragua and nine Nicaraguan government officials as Specially Designated Nationals (SDNs) under Executive Order 13851. According to a Treasury Department news release, the designations are a response to recent “sham” elections and repression of the country’s political opposition. Canada and the UK also announced targeted sanctions against Nicaraguan officials (here and here). (For more information, see my team’s blog post.)
  3. President Biden issued an Executive Order terminating the national emergency with respect to Burundi adopted under Executive Order 13712 in November 2015. According to the new Executive Order and an accompanying presidential statement, the decision follows recent political improvements in Burundi, “including the transfer of power following elections in 2020, significantly decreased violence, and President Ndayishimiye’s pursuit of reforms across multiple sectors.” As explained in a Treasury Department news release, all sanctions under the Burundi-related sanctions program are now lifted, and OFAC will soon revoke its Burundi Sanctions Regulations. (Congrats, Burundi!)
  4. OFAC named six individuals and one entity in Iran as SDNs under Executive Order 13848 targeting foreign interference in US elections. According to a Treasury Department news release, the group obtain information about US voters and oversaw an online campaign to intimidate and disinform voters ahead of the 2020 elections.
  5. OFAC named a senior Houthi military official as an SDN under Executive Order 13611 for overseeing “the Houthis’ seizure of property in Yemen . . . using a variety of unlawful tactics, including extortion.”


OFAC’s latest Nicaragua-related designations include a local banking regulator whose responsibilities include implementing a law “which forbids banks in Nicaragua . . . from refusing financial services to customers, including OFAC-designated persons.” As mentioned earlier, OFAC designated another official responsible for implementing the law in June 2021. Both were sanctioned under Executive Order 13851 for being officials of the Government of Nicaragua.

Check it out: the Association of Certified Anti-Money Laundering Specialists (ACAMS) is running a survey about how companies are dealing with the growing risk of ransomware. This is an important topic if you can spare a few minutes for it. Contact Sam Cousins for more information or click here to take the survey.

Happy Thanksgiving, 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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