Sanctions Top-5 for the week ending 25 February 2022

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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This week’s briefing covers the weeks ending 18 and 25 February 2022.

  1. The US Treasury Department’s Office of Foreign Assets Control (OFAC) issued Directive 4 under Executive Order 14024 prohibiting US persons from transacting with Russia’s Central Bank, National Wealth Fund, and Ministry of Finance. The EU prohibited “transactions related to the management of reserves as well as of assets of the Central Bank of Russia” and persons acting on behalf of, or at the direction of, the bank. Canada also barred its banks from transacting with Russia’s Central Bank and Russian sovereign wealth funds. Other members of the G7 are expected to impose similar restrictions. Earlier, the European Commission, France, Germany, Italy, the United Kingdom, Canada, and the United States issued a joint statement announcing that “selected” Russian banks will lose access to the SWIFT payment network.


To recap: three permanent members of the UN Security Council (the United States, the UK, and France) plus the EU and Switzerland, among others, are laying down punishing sanctions against another permanent member (Russia), with the fifth one (China) caught in the middle. I try to resist hyperbole, but this is the biggest moment for sanctions since the Megarian Decree. New rules are coming out in waves. Some are effective immediately, others will take time. There are differences between regimes. Sanctions practitioners will need to stay on top of them to guide their organizations. No doubt many of you reading this are sorting through a mountain of name screening alerts and making tough decisions. Some activities remain permissible; others will need to be wound down in short order. Hang in there, everyone.

The “Top-5” has always been about sharing information with the global community of practitioners who deal with these issues. Thanks to everyone who has reached out with tips and insights. No doubt I missed some important updates above. For more, see my team’s blog and Russia sanctions resource center. Feel free to post yours in the comments.

In other news, OFAC issued a new general license authorizing certain transactions with governing institutions in Afghanistan that would otherwise be prohibited by OFAC’s terrorism-related sanctions. The license, which has exceptions (including on luxury goods), is meant to clear up questions about transacting with the Government of Afghanistan, including government employees who are not members of the Taliban or the Haqqani Network. OFAC also issued several new FAQs here.

Did I miss something? Send me a message or comment below.

(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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Nicholas Turner

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