Sanctions Top-5 for the week ending 31 July 2020

  1. The US Office of Foreign Assets Control (OFAC) named two Chinese individuals and the Xinjiang Production and Construction Corps (XPCC) as Specially Designated Nationals (SDNs) under the Global Magnitsky Sanctions program for their involvement in human rights abuses in the Xinjiang Uyghur Autonomous Province (XUAR). The XPCC is linked to Chen Quanguo, a PRC government official sanctioned by OFAC in July 2020 for overseeing activities in the XUAR. OFAC also issued General License 2, authorizing US persons to wind down certain XPCC-related activities through 30 September 2020.
  2. The European Union added six individuals and three entities in China, North Korea, and Russia to the EU Sanctions List for their involvement in cyber-related attacks. These are the first designations under the EU’s cyber-related sanctions since the program’s adoption in May 2019. The targets include one Chinese national previously indicted by the US Department of Justice in December 2018 and individuals and entities sanctioned by OFAC in December 2016, September 2018, and December 2018, respectively, including a division of Russia’s Main Intelligence Directorate (GRU).
  3. OFAC announced a US$ 824,314 settlement with a US-based manufacturer for violations of the Iranian Transactions and Sanctions Regulations (ITSR) caused by the company’s subsidiaries in Italy and Turkey. According to the OFAC settlement notice, between 2012 and 2015, the subsidiaries sold products to Iran via distributors in violation of the ITSR at 31 CFR 560.215.
  4. OFAC named a Syrian businessman and nine of his companies as SDNs under the Caesar Syria Civilian Protection Act of 2019 and Executive Order 13582 in connection with luxury shopping and hotel development projects in and around Damascus. The US State Department simultaneously sanctioned three individuals and the First Division of the Syrian Arab Army under Executive Order 13894 in response to atrocities committed by the Syrian military.
  5. The US State Department released a list of 22 materials determined to be used in connection with Iran’s nuclear, military, or ballistic missile programs (who knew there were so many types of aluminum?). The State Department press statement reminds that persons who knowingly transfer such materials to Iran could be targeted with secondary sanctions under Section 1245 of the Iranian Freedom and Counter-Proliferation Act.




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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: