Sanctions Top-5 for the week ending 22 January 2021

Nicholas Turner
3 min readJan 25, 2021

Here are five things that happened this week in the world of economic sanctions that I think you should know about.

Sign up here if you would like to receive these summaries by email. Click here for an index of past Sanctions Top-5 briefings.

  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.


This is the first Sanctions Top-5 since the inauguration. Welcome back, everyone. Expect to see a drop-off in sanctions developments while the Biden administration assesses their options. (I might take a short break, too, if there’s not enough to report.) In the meantime, watch closely for announcements of key appointments of officials who will help shape US policy for the next four years.

On that note, join me in sending a really big congratulations to sanctions gurus Peter Harrell, Elizabeth Rosenberg, and others from the Center for a New American Security (CNAS) who are taking up posts in the administration (see the list here). CNAS has been on the cutting edge of thinking about US sanctions policy these past four years. No doubt they will have a positive impact on the next four years and beyond.

For the criminal defense buffs out there: Join Steptoe partners Brian Heberlig, Wendy Wysong, and me for “US Economic Sanctions and the Ali Sadr Case” to hear about one defendant who overcame charges of violating US sanctions on Iran. Registration is here. See the live version on Thursday, 28 January 2021, at 9:00 a.m. New York time. It’s a great story.

(Research tip: the Trump-era White House and State Department websites have been archived. Go here and here if you want to find documents and news releases from 2017–2021. Some links in older editions of the Sanctions Top-5 might not work for this reason — email me if you need a link to something.)

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.)



Nicholas Turner

US attorney in Hong Kong specializing in economic sanctions, financial crimes. This is an archive of briefings published between 2017 and 2022.