Sanctions Top-5 for the week ending 25 December 2020

  1. The US Commerce Department’s Bureau of Industry and Security (BIS) added a Military End User (MEU) List to the Export Administration Regulations (EAR) containing the names of 57 Chinese and 45 Russian entities. The MEU List identities entities that are subject to a licensing requirement under the EAR’s “military end use / military end user” rule. Don’t confuse it with the Entity List. (More on this below.)
  2. The US State Department announced sanctions against Asma al-Assad, wife of Syrian President Bashar al-Assad, as well as her parents, brother, and uncle (all UK nationals) under Executive Order 13894. According to a State Department news release, the family “has accumulated their ill-gotten riches at the expense of the Syrian people.” (Hey, remember when Asma al-Assad was featured in Vogue?) Meanwhile, the US Office of Foreign Assets Control (OFAC) named the Central Bank of Syria as a Specially Designated National (SDN), along with a Syrian official, her husband, and several government-linked companies.
  3. OFAC named one individual and four entities as SDNs under Executive Order 13405 for their roles in the disputed August 2020 presidential elections in Belarus and suppression of protests. Meanwhile, the US State Department announced a US travel ban on 39 additional individuals found responsible for undermining democracy in Belarus, pursuant to Presidential Proclamation 8015 of 12 May 2006.
  4. OFAC named Cuban state-controlled Grupo de Administración Empresarial S.A. (GAESA) and two of its Panama-incorporated subsidiaries as SDNs under the Cuban Assets Control Regulations (CACR). The Panamanian companies include remittance provider Financiera Cimex S.A. (FINCIMEX) and Kave Coffee, S.A., which exports Cubita brand coffee.
  5. OFAC named three Nicaraguan government officials as SDNs under Executive 13851 for assisting “the [President Daniel] Ortega regime’s effort to undermine Nicaragua’s democracy.” They include a National Assembly member who “publicly supported the controversial Foreign Agents Law” that “will likely be invoked to target key individuals or organizations that the government deems to be a threat.”




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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: