Sanctions Top-5 for the week ending 28 May 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 Office of Foreign Assets Control (OFAC) issued FAQ 896 confirming that Xiaomi Corporation is once and for all no longer subject to Executive Order 13959 following an order from the US District Court for the District of Columbia vacating the US Department of Defense’s designation of the company as a “Communist Chinese military company” (CCMC) on 14 January 2021.


According to reports, EU sanctions on Belarus are expected to focus on the potash, oil, and financial sectors, as well as individuals responsible for the forced landing of Ryanair Flight 4978. An announcement could come within the next couple of weeks. As for the United States, General License №2H was already set to expire on 3 June, as mentioned back in April 2021, so technically that has nothing to do with the Ryanair incident.

The good folks at WorldECR have launched a new journal called Financial Institutions Sanctions Compliance (FISC) edited by Ian Bolton. In issue №1, Wendy Wysong and I explore how Hong Kong financial institutions are adapting to US sanctions. “From where we sit, most FIs have succeeded in understanding and adapting to recent US restrictions with a risk-based approach while continuing to profit from the region’s vibrant economy and roaring capital markets.” (Email to request a free copy of the journal.)

Like the Top-5? Contact me to talk about tailored sanctions briefings for your team. 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.)



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Nicholas Turner

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