Sanctions Top-5 for the week ending 25 December 2020

Nicholas Turner
3 min readDec 28, 2020

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 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.”


Every time the US government publishes a list, an angel gets its wings. Last week, we discussed the differences between the BIS Entity List and the OFAC SDN List. Behold now the MEU List, which identities entities that will trigger a licensing requirement when receiving certain items subject to the EAR, per the military end use / military end user rule. An earlier version of the MEU List was leaked to the press in November. BIS warns, however, that other entities that are not on the MEU List could also be subject to the rule on a case-by-case basis.

One more thing: the MEU List is not to be confused with the list of so-called “Communist Chinese military companies” (CCMC) published by the Department of Defense. Speaking of, OFAC just released several FAQs about the CCMC list — more on that next week. (For more on the MEU List, see my colleagues’ new blog post here.)

The past year has been full of twists, turns, and surprises. Thanks again for reading the Top-5 and a special thanks if you’ve shared, commented, or sent a kind word.

Happy New Year, everyone!

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.)



Nicholas Turner

US attorney in Hong Kong specializing in economic sanctions, financial crimes. This is an archive of briefings published between 2017 and 2022.