Sanctions Top-5 for the week ending 26 March 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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  1. The United States, the EU, the UK, and Canada rolled out coordinated sanctions aimed at a total of four officials and one entity in China in response to alleged human rights abuses in the Xinjiang Uyghur Autonomous Region (XUAR). (Announcements here, here, here, and here.)


Are last week’s PRC sanctions “real” sanctions? In a sense they are because they identify specific targets (e.g., named officials) and consequences (e.g., a visa bans). On the other hand, the statements do not point to a law or regulation authorizing the sanctions, what the penalty for breaching them is, or where to go for guidance. As far as I know, there isn’t a sanctions list to consult, and the announcements provide no identifying information on the targets. Compare this to the fairly detailed Provisions for the Unreliable Entity List (UEL) outlined by the PRC Ministry of Commerce in September 2020. (Interesting the UEL isn’t being used here.)

China is a big and important country, and it has as much right to impose unilateral sanctions as the United States, the EU, and other nations. But its regulatory framework for sanctions is still developing. These announcements will surely be implemented through governmental channels, and Tony Perkins won’t be opening a bank account in China soon. But it’s not quite the SDN List (yet).

OFAC’s sanctions against Myanmar’s MEHL and MEC are a big deal. Join me and Dr. Rocco Macchiavello for a talk hosted by about international sanctions and Myanmar’s economy on Wednesday, 7 April, at 3:00 p.m. Zurich time (9:00 p.m. Hong Kong). Register here.

Did I miss something? Send me a message or comment on LinkedIn. Like the Top-5? Contact me to talk about a tailored sanctions briefing for your team.

(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: