Sanctions Top-5 for the week ending 26 November 2021

Nicholas Turner
3 min readNov 30, 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 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.
  2. The US Office of Foreign Assets Control (OFAC) amended its Syria Sanctions Regulations with an updated general license at 31 CFR §542.516 authorizing a wider range of transactions subject to US jurisdiction in support of not-for-profit activities in Syria. According to a Treasury Department news release, these include engaging in new investment in Syria, purchasing refined petroleum products of Syrian origin (for use in Syria), and engaging in certain transactions with elements of the Syrian government.
  3. The US State Department designated four individuals as Specially Designated Global Terrorists (SDGTs) under Executive Order 13224 for their involvement in the Islamic State’s Khorasan Province (ISIS-K) in Afghanistan. The targets include an individual OFAC refers to as a “financial facilitator” who carries out international financial transactions on behalf of ISIS-K.
  4. Australia’s Minister for Foreign Affairs introduced the Autonomous Sanctions Amendment (Thematic Sanctions) Bill 2021 into the country’s Parliament. The bill would expand Australia’s autonomous sanctions regime to include additional themes such as “Magnitsky-style” human rights sanctions. (The proposed text and explanatory documents are available here.)
  5. Meanwhile, Australia’s Minister for Home Affairs announced the designation of two groups — The Base and Hizballah — as terrorist organizations under the Australian Criminal Code. Hizballah’s External Security Organisation (ESO) was previously designated as a terrorist organization in Australia in 2003.


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.)



Nicholas Turner

US attorney in Hong Kong specializing in economic sanctions, financial crimes. This is an archive of briefings published between 2017 and 2022.