Sanctions Top-5 for the week ending 30 October 2020

  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.)




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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: