Sanctions Top-5 for the week ending 25 June 2021

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 June 2021.

1. US Customs and Border Protection (CBP) issued a Withhold Release Order against silica-based products (used in solar panels and electronics) made by Xinjiang-based Hoshine Silicon Industry and its subsidiaries. Meanwhile, the US Commerce Department’s Bureau of Industry and Security (BIS) added Hoshine and four other companies to the Entity List for allegedly “participating in the practice of, accepting, or utilizing forced labor involving Uyghurs and other Muslim minority groups” in China.
2. The EU, the UK, and Canada teamed up to impose sanctions on a host of individuals and entities in Belarus in response to the forced landing of a Ryanair flight and the arrest of two passengers in May 2021 (announcements here, here, and here). The EU also updated its Belarus-related sanctions to include sectoral sanctions on certain Belarusian entities and other restrictions.
3. Meanwhile, the US Office of Foreign Assets Control (OFAC) named 16 individuals and five entities as Specially Designated Nationals (SDNs) under Executive Order 13405 in response to the situation in Belarus. OFAC also issued General License 3 to authorize US persons to engage in limited transactions with the Belarusian KGB.
4. The EU added eight individuals and three entities in Myanmar, including Myanma Gems Enterprise and Myanma Timber Enterprise, to the EU Sanctions List. The UK added Myanmar Pearl Enterprise, Myanma Timber Enterprise, and the State Administration Council to the UK Sanctions List. (All of the entities were already sanctioned by OFAC.)
5. Better late than never? OFAC issued three general licenses (here, here, and here) authorizing US persons to engage in a wide range of humanitarian activities involving Iran, Syria, and Venezuela in response to the COVID-19 pandemic. OFAC also issued several FAQs to clarify, among other things, that non-US persons aren’t at risk of being sanctioned for providing COVID-19 relief.

Comments

There was a lot of speculation about whether the Biden administration would target Hoshine and other key renewable energy suppliers in Xinjiang. The thinking was that placing restrictions on the companies could undermine efforts to partner with China on climate change. I’d say the White House calculated that American voters prefer getting tough on China over clean energy. According to a Commerce Department news release, BIS has added more than 50 companies to the Entity List in connection with the Xinjiang Province since October 2019. (For more, see this insightful article by Katrina Northrop on The Wire China about BIS’s use of the Entity List to target Xinjiang cotton production.)

How are companies reacting to the latest Myanmar sanctions? Join Gem Conn, Kevin Cahill, and me for a webinar hosted by Dow Jones Risk & Compliance on Wednesday, July 7, at 4:00 p.m. Hong Kong time. Click here for details and to register.

Check it out: The Centre for Financial Crime & Security Studies at the Royal United Services Institute (RUSI) is looking to hire a new Senior Research Fellow. Sanctions mavens apply within.

Like the Top-5? Contact me to talk about tailored sanctions briefings for your team. 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.)