Sanctions Top-5 for the week ending 23 October 2020

  1. The White House formally notified Congress that Sudan would be removed from the State Department’s list of State Sponsors of Terrorism. As mentioned last week, the US Office of Foreign Assets Control (OFAC) lifted its comprehensive sanctions on Sudan in October 2017. (More on this below.)
  2. The US State Department announced that six entities and two individuals in China and Hong Kong were designated as Specially Designated Nationals (SDNs) under Section 1244 of the Iran Freedom and Counter-Proliferation Act. According to a State Department news release, the targets arranged for the sale of container ships to a subsidiary of the Islamic Republic of Iran Shipping Line (IRISL) and arranged for IRISL vessels to berth at ports in China.
  3. OFAC named five Iranian entities as SDNs under Executive Order 13848 for their “brazen attempts to sow discord among the voting populace by spreading disinformation online and executing malign influence operations aimed at misleading US voters.” OFAC also sanctioned Iran’s ambassador to Iraq under Executive Order 13224 for acting for or on behalf of the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF).
  4. The European Union sanctioned two Russian nationals and the 85th Main Centre for Special Services (GTsSS) of the Main Directorate of the General Staff of the Armed Forces of the Russian Federation (a.k.a. “Fancy Bear”) for their roles in a cyber attack on the German Federal Parliament in 2015.
  5. OFAC announced a USD 4,144,651 settlement with a US-based company for violations of the Iranian Transactions and Sanctions Regulations (ITSR). According to the OFAC settlement notice, the company’s indirectly held Turkish subsidiary sold products to distributors with knowledge they would be sold to Iran in breach of the parent’s sanctions policy. (Again: Non-US companies owned or controlled by US persons are subject to the ITSR.)




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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: