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.

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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.
  2. The United Nations Security Council adopted Resolution 2615 (2021) to enable the provision of humanitarian assistance and other activities that support basic human needs in Afghanistan that would others be prohibited under paragraph 1 of Resolution 2255 (2015) pursuant to the UN sanctions regime established by Resolution 1988 (2011).
  3. In related news, the US Office of Foreign Assets Control (OFAC) issued three new general licenses (available here, here, and here) authorizing activities involving the Taliban and the Haqqani Network in Afghanistan that would otherwise be prohibited under OFAC’s terrorism-related sanctions regulations and Executive Order 13224. According to a Treasury Department news release, the licenses are meant to expand the flow of humanitarian aid to Afghanistan and are consistent with the Security Council’s new resolution. (For more on the general licenses, see my team’s blog post here.)
  4. OFAC announced a USD 115,005 settlement with a US-based bank for multiple violations of the North Korea Sanctions Regulations and the Foreign Narcotics Kingpin Sanctions Regulations. According to a Treasury Department news release, the bank maintained accounts for employees of North Korea’s mission to the United Nations without an OFAC license as well as an individual SDN.
  5. OFAC removed dozens of individuals and entities in Colombia from the SDN List who were previously designated under the Foreign Narcotics Kingpin Designation Act and the counter-narcotics sanctions program under Executive Order 12978. OFAC also de-listed Manuel Noriega, the deceased former dictator of Panama, and his wife, Felicidad Sieiro.


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.)




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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