Sanctions Top-5 for the week ending 2 July 2021

  1. The US Office of Foreign Assets Control (OFAC) named 22 individuals in Myanmar as Specially Designated Nationals (SDNs) under Executive Order 14014. The individuals, who are said to be connected to the military regime, include three members of the State Administrative Council (SAC).
  2. In related news, Switzerland’s State Secretariat for Economic Affairs announced sanctions against eight individuals and four entities in Myanmar, The targets include the country’s attorney general, several ministers, and four military-owned entities.
  3. OFAC named one individual in Nigeria as a Specially Designated Global Terrorist (SDGT) under Executive Order 13224. According to a State Department news release, the individual plays a leadership role in the Islamic State of Iraq and Syria in the Greater Sahara (ISIS-GS) in Mali.
  4. OFAC removed two Iranian individuals from the SDN List (unrelated to negotiations over the Joint Comprehensive Plan of Action (JCPOA)). OFAC sanctioned the individuals pursuant to Executive Order 13882 in September 2020 alleging connections to Iran’s nuclear program. (Big congrats to Erich Ferrari and his team who sought the delisting on behalf of their clients.)
  5. Say farewell to 31 CFR part 520 (and good riddance). OFAC officially revoked the International Criminal Court-Related Sanctions Regulations following President Biden’s termination of Executive Order 13928 on 1 April 2021.




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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: