Sanctions Top-5 for the week ending 23 April 2021

  1. The European Union joined the United States, the UK, and Canada in sanctioning Myanmar Economic Corporation (MEC) and Myanmar Economic Holdings Limited (MEHL) and added ten other individuals to the EU Sanctions List. Meanwhile, the US Office of Foreign Assets Control (OFAC) named Myanma Timber Enterprise and Myanmar Pearl Enterprise as Specially Designated Nationals (SDNs).
  2. OFAC announced a USD 435,003 settlement with a US-based manufacturing company for violations of the Iranian Transactions and Sanctions Regulations (ITSR). According to the settlement notice, the Oklahoma-based company “outsourced a significant portion of its engineering work to an Iranian engineering company” in violation of the ITSR’s prohibition on US persons dealing in Iranian-origin services.
  3. OFAC revoked a general license under the Belarus Sanctions Regulations that had authorized US persons to transact with nine Belarusian entities since 2015. OFAC replaced the license with a new one authorizing US persons to wind down their business with the entities (and entities owned 50 percent or more by them) within 45 days. (For more on this, read my colleagues’ blog post here.)
  4. OFAC lifted sanctions on the ex-wife and four adult children of drug trafficker Rafael Caro Quintero. OFAC sanctioned the family members and their companies under the Foreign Narcotics Kingpin Designation Act (FNKDA) in June 2013 for acting on behalf of Caro Quintero. (OFAC sanctioned Caro Quintero’s common-law wife in May 2016.) Caro Quintero himself was designated under the FNKDA in December 2000.
  5. The US Department of Justice (DOJ) announced the seizure of an oil tanker, the M/T Courageous, allegedly used to ship petroleum products to North Korea in violation of UN sanctions. The DOJ also announced charges against a Singaporean national accused of processing transactions through the US financial system in connection with the shipments.




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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: