Sanctions Top-5 for the week ending 3 December 2021

Here are five things that happened this week in the world of economic sanctions that I think you should know about.

Sign up here if you would like to receive these summaries by email. Click here for an index of past Sanctions Top-5 briefings.

  1. The US Office of Foreign Assets Control (OFAC) named 20 individuals and 12 entities in Belarus as Specially Designated Nationals (SDNs) under Executive Orders 14038 and 13405, in a coordinated action with the EU, the UK, and Canada. OFAC also issued a new Directive 1 under Executive Order 14038 prohibiting US persons from dealing in new debt with a maturity of greater than 90 days issued after 2 December 2021 by the Belarusian Ministry of Finance or Development Bank.


The new Belarus-related Directive 1 under Executive Order 14038 is a bit like the Russia-related Directive 1 under Executive Order 14024 from April 2021. (Just don’t confuse them with Directive 1 under Executive Order 13662, also Russia-related.) Importantly, new FAQ 943 makes it clear that OFAC’s 50 Percent Rule does not apply to the new Directive. (For more on OFAC’s action, including the new General License №5, see my team’s blog post here.)

Speaking of Russia, remember when Executive Order 13685 dropped in mid-December 2014 creating the US embargo of Crimea and spoiling the holidays for hardworking sanctions compliance officers everywhere? Well, according to media reports, the United States and the EU are readying “substantial” new sanctions just in case Russia makes a move into Ukraine in the coming weeks. No official word on who would go on the naughty list.

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.)



Get the Medium app

A button that says 'Download on the App Store', and if clicked it will lead you to the iOS App store
A button that says 'Get it on, Google Play', and if clicked it will lead you to the Google Play store
Nicholas Turner

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