Sanctions Top-5 for the week ending 30 April 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 UK unveiled a Global Anti-Corruption sanctions regime targeting bribery and misappropriation of property involving public officials. According to an explanatory memorandum from the Foreign, Commonwealth and Development Office, the regime is part of the UK government’s wider anti-corruption strategy and aims “to protect democratic values and promote effective governance.” The UK Foreign Secretary inaugurated the regime by announcing sanctions against 22 individuals in Russia, South Africa, South Sudan, and Latin America.


OFAC is cranking out the settlements lately. This week brings us two cases showing that sanctions compliance is one part technology and one part people. (Or maybe two parts technology.) In the first case, the money transmitter failed to identify SDN transactions in part due to “screening, technology, and fuzzy logic failures” as well as “limited instances of human error” where analysts confused prohibited commercial transactions with permissible personal remittances. In the second case, the software company failed to implement geolocation and IP-blocking controls to prevent users in sanctioned territories from downloading and accessing its products. Meanwhile, a compliance team responsible for the cloud-services business “was not resourced or empowered to manage these processes appropriately.

Both companies received mitigation credit for beefing up their compliance programs after discovering the apparent violations.

Check out this article from the South China Morning Post about the EU’s reaction to the PRC sanctions announced by the Ministry of Foreign Affairs in March 2021. According to the author: “China’s sanctions — unlike those imposed by Western countries that were based on the Global Magnitsky Act or similar frameworks — are not defined by Chinese laws.” If that sounds familiar, it’s because I made this point myself back in March when the sanctions were first announced. I wrote: “[T]he statements do not point to a law or regulation authorizing the sanctions, what the penalty for breaching them is, or where to go for guidance.” The PRC’s sanctions framework is a work in progress.

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:

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: