Sanctions Top-5 for the week ending 23 July 2021

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 PRC Ministry of Foreign Affairs (MFA) announced “reciprocal sanctions” under the recently adopted Anti-Foreign Sanctions Law against seven targets in the United States in response to the sanctioning of seven PRC officials by the US Office of Foreign Assets Control (OFAC) and the issuance of the US government’s Hong Kong business advisory last week (more on that here). The targets include former Commerce Secretary Wilbur Ross. the Chairman of the US-China Economic and Security Review Commission, and the Hong Kong Democracy Council.
2. The UK Foreign & Commonwealth Office announced sanctions against five individuals in Equatorial Guinea, Zimbabwe, Venezuela, and Iraq under the UK Global Anti-Corruption sanctions regime. The targets include the son of the current president of Equatorial Guinea (who also happens to be the vice president) and two Venezuelan businessmen accused of profiting from a government-run food and housing program.
3. The US State Department announced sanctions against Cuba’s Minister of the Revolutionary Armed Forces and the Cuban Ministry of the Interior’s Special National Brigade under the Global Magnitsky Sanctions program. According to a State Department news release, the targets were sanctioned in response to their roles in suppressing recent protests in Cuba.
4. OFAC announced a pair of settlements with the Dubai- and US-based subsidiaries of a Swedish manufacturing company for violations of the Iranian Transactions and Sanctions Regulations (ITSR). According to the OFAC settlement notices (here and here), the companies conspired to export products from the United States to Iran via Dubai in violation of the ITSR. The financial penalties in the cases were USD 415,695 and 16,875, respectively.
5. OFAC announced a USD 1,400,301 settlement with a publicly traded, US-based online payments and prepaid services provider for violations of multiple OFAC programs. According to the OFAC settlement notice, the company processed transactions in relation to US-comprehensively sanctioned territories and Specially Designated Nationals (SDNs) and failed to adequately test its sanctions compliance and name screening program.

Comments

The MFA announcement did not specify the type of sanctions adopted against Wilbur Ross and the other targets under the Anti-Foreign Sanctions Law. However, it’s worth noting that the wording of the announcement is basically the same as the announcements made before the Anti-Foreign Sanctions Law’s adoption in June 2021. (For more context on this issue, check out my commentary from June.)

Interested in supporting scholarship? A scholar in economic sanctions at a US university is writing about how the private sector experiences the risks and challenges of sanctions compliance, how this affects their withdrawal from markets, and the humanitarian effects. She is looking for practitioners to share their insights. She is particularly interested in speaking to people who are engaged with African banks, nongovernmental organizations, and developing markets. Drop me a line if you can help, and I will put you in touch. Thanks!

On that note, if you are a researcher or just want to refresh your memory on recent sanctions developments, feel free to browse the index of Sanctions Top-5 briefings from 2017 to 2021 (including all major Trump administration actions).

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(The views expressed are my own and do not constitute legal advice. Photo from Vladislav Reshetnyak.)