Sanctions Top-5 for the week ending 21 January 2022

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 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.”


Recent events in Myanmar and Mali underscore the growing influence of NGOs in the sanctions-making process. NGOs play a role by gathering evidence and promoting new sanctions, helping to identify targets for sanctions, advocating for humanitarian exceptions, and drawing attention to sanctions that harm vulnerable peoples. Their work is reflected in the US Treasury Department’s recent 2021 Sanctions Policy Review as well as recent Afghanistan-related general licenses and numerous SDN designations under the Global Magnitsky Sanctions program. They are also helping to inform the actions of corporations, as demonstrated by Human Rights Watch’s interactions with TotalEnergies last week.

Check out the latest issue of FISC Journal edited by Ian Bolton, from the publisher of WorldECR. There’s an interview with the International Compliance Association’s Ross Savage and a lot more. (Shout out to my colleagues at Steptoe for their piece on the very interesting Ali Sadr case.)

Speaking of great resources, UK Finance is hiring a Sanctions Policy Manager. Check out the job posting here.

Coming up in a bit: I’ll be speaking with HashKey Group’s Angelina Kwan, Refinitiv’s Michael Meadon, and Regulation Asia’s Brad Maclean about Russia/Ukraine, China, cryptocurrency, and more, at the APAC Financial Crime Outlook 2022 webinar hosted by Refinitiv on Tuesday, 25 January, at 10:00 a.m. Hong Kong time. Details and registration here.

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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

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