Sanctions Top-5 for the week ending 22 January 2021

  1. China’s Ministry of Foreign Affairs announced sanctions against 28 Americans (some unnamed) for “seriously disrupt[ing] China-US relations” among other things. The targets include former Secretary of State Mike Pompeo and several high-level Trump administration officials. Usually, I say that PRC sanctions are “unspecified.” In this case, the announcement specifies the “individuals and their immediate family members are prohibited from entering” China (including Hong Kong and Macao). Additionally, “companies and institutions associated with them are also restricted from doing business with China.” Not sure who those companies and institutions are — sure they’ll find out soon enough.
  2. The US Office of Foreign Assets Control (OFAC) named three individuals, 14 entities, and six vessels as Specially Designated Nationals (SDNs) pursuant to Executive Order 13850 for engaging in illicit exports of Venezuelan petroleum. The newly designated entities are located in Italy, Malta, New York, Panama, Switzerland, Ukraine, the United Kingdom, Venezuela, and Zimbabwe. According to a Treasury Department news release, the targets are related to a Mexico-based network designated in June 2020.
  3. The US State Department named Yemen-based Ansar Allah (a.k.a. the Houthi movement) and three of its leaders as Specially Designated Global Terrorists (SDGTs) under Executive Order 13224. Meanwhile, OFAC issued four general licenses intended to support continued humanitarian aid to Yemen. (The US State Department had announced its intention to designate the group as an SDGT on 10 January 2021.)
  4. The US State Department announced menu-based sanctions on a Russia-based company and one vessel under Section 232 of the Countering America’s Adversaries Through Sanctions Act (CAATSA) for their roles in the construction of the Nord Stream 2 energy pipeline.
  5. The European Parliament adopted a resolution urging the European Council to “consider the introduction of targeted sanctions against individuals in Hong Kong and China” in response to recent events. The resolution also “[c]ondems the role of European-based banks in . . . freezing the assets and bank accounts” of certain high-profile individuals.




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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: