Sanctions Top-5 for the week ending 25 December 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.)


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.)



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Nicholas Turner

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