Sanctions Top-5 for the week ending 29 October 2021

Nicholas Turner
3 min readNov 1, 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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This week’s briefing covers the weeks ending 22 and 29 October 2021.

  1. The US Treasury Department released a report summarizing the outcomes of its review of US sanctions policy since 2001. The report outlines a policy framework emphasizing multilateral sanctions, minimizing unintended collateral damage, “ensuring sanctions are easily understood, enforceable, and, where possible, reversible,” and investing in Treasury Department resources and skilled personnel. US sanctions should also be linked to clear policy objectives, the report says. Deputy Treasury Secretary Wally Adeyemo gave more details about the review in his testimony to the Senate Banking Committee. (The full report is available here.)
  2. The US Office of Foreign Assets Control (OFAC) named three individuals in Lebanon, including two businessmen and a member of parliament, as Specially Designated Nationals (SDNs) under Executive Order 13441 for engaging in corruption and “contributing to the breakdown of the rule of law in Lebanon.”
  3. OFAC named four individuals and three entities as SDNs under Executive Orders 13224 (terrorism) and 13382 (weapons of mass destruction) for their support of Iran’s development of unmanned aerial vehicles (UAVs). According to a Treasury Department news release, the UAVs have been used by Iranian-supported militant groups and to attack ships in the region.
  4. The UN Security Council committee established pursuant to resolution 1970 (2011) added one individual to the UN Sanctions List for participating in human rights abuses against African migrants at the al-Nasr Detention Center in Zawiyah, Libya. OFAC also added the individual to the SDN List.
  5. The Government of Kosovo announced an asset freeze and travel ban against seven individuals and one company accused of supporting Hezbollah. The United States and Qatar announced coordinated sanctions against the group last month.


The Treasury Department’s sanctions review appears to reflect a growing recognition among US policymakers that sanctions are not a silver bullet. Specifically, the review acknowledges that sanctions have the potential to boost alternatives to the US financial system (including virtual currencies), impose losses on US businesses, and harm vulnerable populations. At the same time, “maximum pressure” has had limited success at subduing foreign adversaries. Importantly, the report plays up the importance of multilateralism as one solution and emphasizes the need to protect humanitarian trade. But no one is saying US sanctions must adhere to the principles in the report, and the Treasury Department is but one of the agencies responsible for formulating US sanctions policy. Still, a good palate cleanser.

Fretting over supply chain risk? Have I got the event for you! Join us for the “Responsible Supply Chains in Asia” webinar featuring Archana Kotecha, founder of The Remedy Project, and Dr. Wan Yee Lam, Managing Consultant at South Pole, where we’ll talk about ways companies and their suppliers are fighting climate change and forced labor in the region. The (free) event is part of the Social Impact Series hosted by the American Chamber of Commerce in Hong Kong and is sponsored by Steptoe & Johnson Hong Kong. Tune in on Tuesday, 9 November, at 8:30 a.m. Hong Kong time. Get more details and sign up at this link.

Also coming up: the New York chapter of the Association of Certified Anti-Money Laundering Specialists (ACAMS) will host a “Current Events and Hot Topics in Sanctions” panel on 9 November at 5:30 p.m. New York time. Contact chapter co-chair Howard Spieler or visit this link for more info.

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.