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.


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.)



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Nicholas Turner

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