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.
  2. Third time’s a charm?GOWIN Semiconductor Corporation filed suit in the DC District Court challenging its designation as a CCMC and seeking its own preliminary injunction against enforcement of Executive Order 13959. GOWIN is the third company after Xiaomi and Luokung Technology Corp. to take the Pentagon to court over the CCMC label.
  3. The White House issued a statement announcing that OFAC will “re-impose full blocking sanctions against nine Belarusian state-owned enterprises” on 3 June 2021 and that the United States “is developing a list of targeted sanctions against key members of the Lukashenka regime” with the EU and other allies, after the Belarusian government allegedly forced a Ryanair jet to land in Minsk for the purpose of arresting a passenger. The statement also hinted at a forthcoming executive order authorizing new sanctions.
  4. China’s Ministry of Foreign Affairs announced a travel ban against a former commissioner of the United States Commission on International Religious Freedom (UNCIRF) and his family[i]n response to the US blatant move to endorse cults and impose unilateral sanctions on Chinese personnel based on lies and disinformation.” (Earlier this month, the US State Department imposed a visa ban on a Chinese official and his immediate family members in response to alleged abuses against Falun Gong practitioners in conjunction with the 2020 International Religious Freedom Report.) In a statement, the UNCIRF noted that the State Department’s report “is entirely separate and independent from USCIRF.”
  5. US Customs and Border Protection (CBP) issued a Withhold Release Order against imports of seafood into the United States harvested by vessels owned or operated by Dalian Ocean Fishing Co., Ltd., a Chinese fishing company, “based on information that reasonably indicates the use of forced labor in the entity’s fishing operations.


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.)

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

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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:

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