Sanctions Top-5 for the week ending 3 December 2021

  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.
  2. In related news, the EU, the UK, and Canada announced their own targeted financial sanctions against individuals and entities in Belarus (announcements here, here, and here). The UK targets include Belaruskali, a major Belarusian potash producer that OFAC designated as an SDN in August 2021.
  3. The US State Department announced the revocation of the designations of the Revolutionary Forces of Colombia (FARC) as a Foreign Terrorist Organization (FTO) and as a Specially Designated Global Terrorist (SDGT), along with numerous individuals. Meanwhile, the State Department designated the Revolutionary Armed Forces of Colombia — People’s Army (FARC-EP) and Segunda Marquetalia — FARC splinter groups created after the country’s 2016 peace accords — as FTOs and SDGTs.
  4. Australia’s Parliament adopted a bill and regulations creating “Magnitsky-style and other thematic sanctions.” As mentioned last week, the measures expand Australia’s autonomous sanctions regime to address human rights violations and abuses, serious corruption, and significant cyber incidents, among other potential issues.
  5. The US Senate voted to confirm Brian Nelson as the US Treasury Department’s Under Secretary for Terrorism and Financial Crimes, a key position for US sanctions policy.




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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: