Sanctions Top-5 for the week ending 31 December 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.

This week’s briefing covers the weeks ending 31 and 24 December 2021.

  1. The US State Department issued an updated report under Section 5(a) of the Hong Kong Autonomy Act (HKAA) adding the names of five Chinese officials following Hong Kong’s Legislative Council elections in December 2021. Financial institutions that knowingly engage in “significant” transactions with persons named in the Section 5(a) report could face secondary sanctions. All five of the officials were previously identified as Specially Designated Nationals (SDNs) under Executive Order 13936 in July 2021.


Happy 2022, everyone!

If you’re looking for a roundup of sanctions developments over the past year, head on over to the Sanctions Top-5 index. (The index has all the briefings since May 2017.) My assessment? 2021 felt a lot like 2020 as far as sanctions go, albeit somewhat less chaotic. With few exceptions, the Biden administration has kept in place or expanded Trump-era policies while toning down the rhetoric and playing up humanitarian exceptions. “Communist Chinese military companies” became “Chinese Military-Industrial Complex Companies” under version 3 of Executive Order 13959. The United States is still sitting out the Joint Comprehensive Plan of Action (JCPOA) with Iran. And there are new sanctions related to Belarus, Counter-narcotics, Ethiopia (Eritrea, really), Myanmar, and Russia. Meanwhile, China stepped up with a (still evolving) anti-foreign sanctions regime.

What will the new year bring? I’m still keeping an eye on Russia/Ukraine. I’d love to hear your predictions in the comments section.

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.)



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: