Sanctions Top-5 for the week ending 30 July 2021

  1. According to reports, China’s National People’s Congress may consider a draft bill to incorporate elements of the recently adopted PRC Anti-Foreign Sanction Law into Hong Kong’s Basic Law. It’s too soon to say what the impact could be. (More on this below.)
  2. The US Office of Foreign Assets Control (OFAC) named eight prisons in Syria and five senior security officials as Specially Designated Nationals (SDNs) under Executive Orders 13894 and 13572. According to a Treasury Department news release, the facilities are “run by the Assad regime’s intelligence apparatus” and are linked to serious human rights abuses committed since 2011. OFAC also sanctioned Ahrar al-Sharqiya, a militant group, under Executive Order 13894 in response to a litany of abuses against Syrian civilians.
  3. OFAC named the Policia Nacional Revolucionaria (PNR) of the Cuban Ministry of the Interior and the PNR’s director and deputy director as SDNs under Executive Order 13818 (Global Magnitsky Sanctions) in response to their “actions to suppress peaceful, pro-democratic protests in Cuba.” The week before, OFAC sanctioned Cuba’s Minister of the Revolutionary Armed Forces and the Cuban Ministry of the Interior’s Special National Brigade, also under the Global Magnitsky program.
  4. The EU Council adopted a framework for imposing targeted sanctions — including asset freezes and travel bans — against persons found responsible for undermining democracy or the rule of law in Lebanon. According to a European Council news release, the measures are part of the EU’s efforts to encourage “Lebanese leadership [to] put aside their differences and work together to form a government” amid the current political and economic crisis.
  5. The US Department of Justice (DOJ) announced the seizure of the tanker M/T Courageous, whose owner (a Singapore national) stands accused of orchestrating sales of petroleum products to North Korea and laundering payments through the US financial system in violation of US and UN sanctions. The vessel was taken into custody in Cambodia in March 2020 after engaging in a ship-to-ship transfer with a sanctioned North Korean vessel.




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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: