Sanctions Top-5 for the week ending 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.




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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: