Sanctions Top-5 for the week ending 29 May 2020

  1. The big news: Donald Trump held a news conference on Friday to announce his administration would “begin the process” of revoking Hong Kong’s separate status from mainland China under US laws. This could include imposing heightened export controls under the Export Administration Regulations (EAR) and other steps. Additionally, the United States is expected to impose sanctions against Chinese and Hong Kong officials responsible for the erosion of Hong Kong’s autonomy. (For more on this issue, see my team’s Client Advisory.)
  2. The US House of Representatives voted 413–1 to pass the Uyghur Human Rights Policy Act of 2020. The bill — now awaiting the president’s signature — calls for sanctions against foreign persons, including government officials, determined to be responsible for human rights abuses in the Xinjiang Uighur Autonomous Region (XUAR).
  3. The US Department of Justice (DOJ) unsealed an indictment against 28 North Korean and 5 Chinese nationals for laundering more than USD 2.5 billion through the global financial system on behalf of North Korea’s Foreign Trade Bank (FTB). The individuals are charged with operating an extensive network of front companies in Russia, Kuwait, Thailand, and other countries to procure goods and make payments related to North Korea. (The indictment is available here.)
  4. The US State Department announced it would not renew secondary sanctions waivers for companies providing services to Iran’s nuclear program under the Joint Comprehensive Plan of Action (JCPOA). The companies will have 60 days to wind down their activities, according to a press statement. At the same time, the State Department announced sanctions on two individuals in the Atomic Energy Organization of Iran.
  5. Justine Walker, the Global Head of Sanctions and Risk for the Association of Certified Anti-Money Laundering Specialists (ACAMS), published a long-awaited and really excellent paper entitled “Risk Management Principles Guide for Sending Humanitarian Funds into Syria and Similar High-Risk Jurisdictions,” with the support of the European Commission, Swiss Agency for Development and Cooperation, UK Department for International Development, the Graduate Institute of Geneva, and the World Bank.

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