Sanctions Top-5 for the week ending 25 September 2020

  1. The US Office of Foreign Assets Control (OFAC) announced amendments to the Cuban Assets Control Regulations (CACR) to prohibit US persons from importing Cuban-origin alcohol and tobacco products and partaking in professional meetings and certain public events in Cuba. Meanwhile, the US State Department announced the creation of the “Cuba Prohibited Accommodations List” containing names of hotels and other businesses that are off limits for individuals engaging in licensed travel to Cuba under the CACR. It wouldn’t be an election year without Cuba sanctions.
  2. OFAC replaced General License 2 under the Global Magnitsky Sanctions program with a new “General License 2-A,” which extends the deadline for US persons to wind down transactions with certain subsidiaries of Xinjiang Production and Construction Corps (XPCC) until 30 November 2020. In related news, Forbes published an article highlighting Uzbekistan’s efforts to eliminate forced labor in its cotton industry under an initiative championed by reformist President Shavkat Mirziyoyev. Uzbek cotton could get a boost as nearby Xinjiang comes under scrutiny, the author writes.
  3. OFAC issued Frequently Asked Question (FAQ) 840 under the recently created Hong Kong-related sanctions program. The FAQ confirms that US persons are not prohibited from dealing with the Hong Kong government, but must exercise caution to avoid dealing, directly or indirectly, with SDN government officials sanctioned under Executive Order 13936.
  4. OFAC announced a USD 473,157 settlement with a US-based wireless technology company for apparent violations of the Iranian Transactions and Sanctions Regulations (ITSR) committed by a Finnish subsidiary. Of note: according to the settlement notice, the violations concerned foreign-produced items containing more than 10% US-origin controlled content which required a license for export to Iran under the Export Administration Regulations (EAR). (One spot where the ITSR and EAR overlap.) Also of note: the company’s non-US employees tried to hide the transactions from the US parent company.
  5. The European Union added two individuals and three entities to the EU Sanctions list for engaging in human rights abuses in Libya and violating the UN’s Libyan arms embargo. The targets include one airline and two shipping companies accused of transferring arms and military material to Libya.




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