Sanctions Top-5 for the week ending 26 November 2021

  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.




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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: