Sanctions Top-5 for the week ending 26 November 2021

Here are five things that happened this week in the world of economic sanctions that I think you should know about.

Sign up here if you would like to receive these summaries by email. Click here for an index of past Sanctions Top-5 briefings.

  1. The US State Department announced the designation of one entity and one vessel under the Protecting Europe’s Energy Security Act of 2019 (PEESA) for being involved in the (nearly there) Nord Stream 2 pipeline. Meanwhile, the German government is reportedly urging Congress not to include new Nord Stream 2 sanctions in the forthcoming National Defense Authorization Act (NDAA) for Fiscal Year 2022.


According to a news release from Australia’s Department of Foreign Affairs and Trade (DFAT), the new autonomous sanctions bill will “enable Australia to respond more flexibly and swiftly to a range of situations of international concern” and adopt targeted sanctions in coordination with allies. The sanctions will include asset freezes and travel bans to prevent Australia from being “an isolated, attractive safe haven” for wrongdoers “and their ill-gotten gains.” The first thematic regimes under the amended law are expected to target serious human rights violations and abuses, serious corruption, and significant cyber incidents. No word yet on who might be targeted.

Nothing says autumn like the NDAA. The annual bill is a must-pass piece of legislation that almost always includes congressional sanctions. The NDAA 2022, complete with new Nord Stream 2 sanctions, is currently under review in the US Senate. And in case you missed it, the US-China Economic and Security Review Commission released its 2021 annual report to Congress. The 551-page report offers a cornucopia of proposals for legislative and executive actions on China, including plentiful sanctions and export controls. (Read the full report here.)

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.)



Get the Medium app

A button that says 'Download on the App Store', and if clicked it will lead you to the iOS App store
A button that says 'Get it on, Google Play', and if clicked it will lead you to the Google Play store
Nicholas Turner

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