Sanctions Top-5 for the week ending 20 March 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. The US State Department announced the imposition of secondary sanctions against nine companies located in South Africa, Hong Kong, China, and Iran under Executive Order 13846 for their involvement in “a significant transaction for the purchase, acquisition, sale, transport, or marketing of petrochemical products from Iran.
  2. In related news, the US Office of Foreign Assets Control (OFAC) named five companies in the United Arab Emirates as Specially Designated Nationals (SDNs) under Executive Order 13846 for collectively purchasing “thousands of metric tons of petroleum products from the National Iranian Oil Company (NIOC)” for delivery to the United Arab Emirates. According to a Treasury Department news release, some of the shipments were falsely identified as Iraqi-origin.
  3. The US State Department announced the designation of Syria’s Defense Minister as an SDN pursuant to Executive Order 13894 for “his deliberate actions since December 2019 to prevent a ceasefire from taking hold in northern Syria.” Meanwhile, the State Department designated the new leader of the Islamic State of Iraq and Syria (ISIS) as a Specially Designated Global Terrorist (SDGT) pursuant to Executive Order 13224.
  4. OFAC removed several entities and two individuals from the SDN List, including companies in the Democratic Republic of the Congo sanctioned in June 2018 under the Global Magnitsky Sanctions program and two Switzerland-based companies sanctioned in December 2014 for facilitating fuel shipments to Syria. Most of the newly de-listed companies have since gone out of business, according to this helpful rundown by Kharon.
  5. The Undersecretary for the US Department of Commerce’s Bureau of Industry and Security (BIS) vacated and remanded a USD 31 million civil monetary penalty imposed by an administrative law judge (ALJ) for violations of the Export Administration Regulations (EAR). The case involved the export of U.S.-origin seismic equipment to Iranian territorial waters by a Singapore company. The Undersecretary upheld the charges but found that the penalty was not proportionate based on similar cases. (Read more about it in our post on the Steptoe International Regulation & Compliance (IRC) Blog.)


The US maximum pressure campaign against Iran continues unabated. Last week brought not one, but two rounds of secondary sanctions designations pursuant to Executive Order 13846 aimed at discouraging trade in Iranian petroleum and petrochemicals. The latest actions echo the Treasury and State Departments’ 23 January 2020 sanctioning of numerous companies and individuals in China, Hong Kong, and Dubai for engaging in significant transactions involving Iranian petroleum and petrochemicals. US sanctions are intended to “deprive the regime of critical income . . . and further Iran’s economic and diplomatic isolation,” US Secretary of State Mike Pompeo said in a statement accompanying the State Department announcement.

Meanwhile, the French government announced a prisoner swap involving an Iranian national, Jalal Rohollahnejad, and a French national held in Iran. The US State Department criticized France’s decision, noting in a statement that Rohollahnejad was subject to a US extradition request. Last week, BIS added Rohollahnejad to the Entity List for procuring goods in China on behalf of an Iranian company sanctioned in July 2017.

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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