Sanctions Top-5 for the week ending 21 January 2022

  1. The US Office of Foreign Assets Control (OFAC) named four individuals as Specially Designated Nationals (SDNs) under Executive Order 14024 for allegedly carrying out destabilizing activities in Ukraine on behalf of Russia’s Federal Security Service. According to a Treasury Department news release, the targets include an individual who controls several news outlets used to “denigrate senior members of Ukrainian President Volodymyr Zelenskyy’s inner circle” and publish “false assertions about US political candidates.”
  2. OFAC named three individuals and a travel company as Specially Designated Global Terrorists (SDGTs) under Executive Order 13224 for allegedly acting as financial facilitators for Hizballah in Lebanon. According to a Treasury Department news release, the targets have helped Hizballah gain “access to material and financial support through the legitimate commercial sector” and exploit Lebanon’s economic resources.
  3. In related news, OFAC named three individuals and ten companies in Lebanon, Germany, and Zambia as SDGTs under Executive Order 13224 for allegedly operating an international commercial network used to raise and launder funds on behalf of Hizballah. According to a Treasury Department news release, one of the individuals is the business partner of an individual named as a SDGT earlier in the week (see above).
  4. Human Rights Watch published a letter from France’s TotalEnergies stating that the company “supports the implementation” of targeted sanctions against financial flows from certain energy projects in Myanmar involving Myanma Oil and Gas Enterprise (MOGE). According to a Human Rights Watch news release, the company’s statement came in response to a December 2021 letter “urging the company to support sanctions to stop gas payments to Myanmar military-controlled entities.” Both TotalEnergies and Chevron have announced their withdrawal from projects in Myanmar due to the deteriorating political situation in the country.
  5. A group of 13 nongovernmental organizations (NGOs) including the International Rescue Committee published a statement urging members of the Economic Community of West African States (ECOWAS) to commit to humanitarian exceptions to a wide-ranging package of Mali-related sanctions announced earlier this month. The ECOWAS “sanctions will have devastating consequences for the people and the humanitarian situation in Mali,” according to the group’s statement. (For more on the ECOWAS sanctions, see last week’s Sanctions Top-5 briefing here.)




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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: