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Sanctions Top-5 for the week ending 24 May 2019

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 US Office of Foreign Assets Control (OFAC) named eight individuals and eight entities in Argentina, Colombia, Canada, the United Kingdom, and the Netherlands as Specially Designated Nationals (SDNs) pursuant to the Foreign Narcotics Kingpin Designation Act. The targets are accused of drug trafficking and money laundering as part of a criminal network associated with the Goldpharma online pharmacy.


Apropos the S-400-related INKSNA sanctions, Turkey’s defense minister told reporters last week the country was preparing for potential US sanctions under the Countering America’s Adversaries Through Sanctions Act (CAATSA) after deciding to purchase the S-400 system. Meanwhile, India’s Ambassador to the United States said India is hoping to shift some defense spending to US suppliers after the country signed its own deal to purchase the S-400 system from Russia last year. The CAATSA sanctions were previously used against a unit of the Chinese military and its director in September 2018.

The concept behind the South China Sea and East China Sea Sanctions Act reminds me of Executive Order 13685, which has been used to target companies involved in construction projects in Crimea. Are sanctions effective at halting development in disputed areas? Are they the right way to resolve territorial disputes? This is the third time the Act has been introduced in the Senate since 2016.

As described in The Wall Street Journal, the Venezuela case seems like a clear example of trade-based money laundering involving over-pricing of goods. Could make an excellent case study for your next AML training.

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.)

US attorney in Hong Kong specializing in economic sanctions, financial crimes. Sign up for emails: LinkedIn at:

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