Sanctions Top-5 for the week ending 20 November 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 Office of Foreign Assets Control (OFAC) named 51 Iranian entities and 10 individuals as Specially Designated Nationals (SDNs) under Executive Order 13876 for their connections to Iran’s supreme leader. According to a Treasury Department news release, the entities are controlled by the Islamic Revolution Mostazafan Foundation (a.k.a. Bonyad Mostazafan).


Another week, another Iran sanctions update. (Newly ascertained) President-elect Biden has signaled his intention to reenter he Joint Comprehensive Plan of Action (JCPOA) with Iran (among other agreements). Secretary of State Mike Pompeo last week warned in a statement that easing of Iran sanctions would be a “dangerous choice” and said the United States would continue to “impose new sanctions on Iran, including using our nuclear, counterterrorism, and human rights authorities” in the “coming weeks and months.”

After four years of heaping on sanctions, it will be interesting to see which ones the Biden administration could offer to bring Iran back to the negotiating table. There are lots to choose from. At the same time, Tehran could demand a premium, if not a guarantee the sanctions will stay lifted. What do you think? Does the United States need Iran’s OK to reenter the JCPOA? Will the Biden administration use its leverage to demand new concessions? Would Iran get a better deal or a worse one under a hypothetical JCPOA 2.0?

I’m looking forward to talking later today about detecting sanctions circumvention at the virtual AML/CTF Annual Summit hosted by Fintelekt and the Philippines Anti-Money Laundering Council. Checkout the details of the five-day program at this link.

Happy Thanksgiving!

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.)



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Nicholas Turner

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