Sanctions Top-5 for the week ending 30 October 2020

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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  1. The US Office of Foreign Assets Control (OFAC) named eight entities in China, Hong Kong, and Singapore as Specially Designated Nationals (SDNs) under Executive Order 13846 for their involvement in sales of Iranian petrochemical products. According to a Treasury Department news release, the entities are linked to Hong Kong-based Triliance Petrochemical Co. Ltd., which OFAC sanctioned in January 2020. In September 2020, OFAC sanctioned 11 Triliance-linked entities in Iran, China, Hong Kong, and the United Arab Emirates.
  2. In related news, the US State Department named five entities and five individuals in Iran, China, and Singapore as SDNs under Executive Order 13846 for Iran-related petroleum transactions. Meanwhile, the US Department of Justice announced the filing of a forfeiture complaint against a shipment of Iranian missiles seized en route to Yemen in August 2020 and the sale of 1.1 million barrels of Iranian gasoil seized from four vessels en route to Venezuela in July 2020.
  3. In yet more Iran sanctions news, OFAC and the State Department designated eight individuals, 11 entities, and two vessels as Specially Designated Global Terrorists (SDGT) under Executive Order 13224 for petroleum transactions linked to Iran’s Islamic Revolutionary Guard Corps (IRGC). At the same time, OFAC issued an updated General License 8A and updated six Frequently Asked Questions (FAQs) on humanitarian transactions involving SDGTs.
  4. OFAC issued amendments to three general licenses under the Cuban Assets Control Regulations (CACR) to prohibit persons subject to US jurisdiction from engaging in licensed remittance transactions that involve entities on the US State Department’s List of Restricted Entities and Subentities Associated with Cuba. The new rule is effective from 26 November 2020.
  5. A spokesperson for the PRC Foreign Ministry announced that China would impose unspecified sanctions on several big-name US defense contractors for planned sales of defensive weapons to Taiwan pursuant to the US Taiwan Relations Act of 1979. (With the recently adopted PRC Export Control Law and Provisions for the Unreliable Entity List, these announcements could come with “specified sanctions” someday.)


It’s Tuesday morning here in Hong Kong. Election-day polls in the United States will open in about 12 hours. By tomorrow in Asia, we could know the outcome of the presidential and most congressional races (or maybe not). I started writing the Sanctions Top-5 in 2017 as an outlet for thinking about sanctions under the then-new Trump presidency. Thank you to everyone who has read, commented, and contributed over the past three-and-a-half years. It’s been fun! (Find the index of past briefings here.)

What will this year’s elections mean for US sanctions? If the past four years have shown us anything, it’s that elections matter bigly when it comes to sanctions policy. There have been massive shifts on Iran, Cuba, Venezuela, China, Hong Kong, human rights, and technology export controls, to name just a few areas. (For more on the elections and sanctions, check out this podcast from Royal United Services Institute (RUSI) featuring Emil Dall, Elizabeth Rosenberg, Sascha Lohmann, and me.)

Bonus item: OFAC issued an advisory on the risks associated with high-value artwork owned by SDNs. While art can be exempted from some OFAC regulations as an “informational material,the advisory clarifies that the exemption would not apply “to the extent the artwork functions primarily as an investment asset or medium of exchange.” Ceci n’est pas un blocked asset! Or is it?

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:

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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:

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