Sanctions Top-5 for the week ending 4 December 2020

  1. The US Department of Defense added four names to the list of so-called “Communist Chinese military companies” under Section 1237 of the National Defense Authorization Act (NDAA) for Fiscal Year 1999. They are: China Construction Technology Co. Ltd. (CCTC), China International Engineering Consulting Corp. (CIECC), China National Offshore Oil Corp. (CNOOC), and Semiconductor Manufacturing International Corp. (SMIC). (More on this below.)
  2. The US Office of Foreign Assets Control (OFAC) named China National Electronics Import & Export Corporation (CEIEC) as a Specially Designated National (SDN) under Executive Order 13692 for helping the Venezuelan government monitor and restrict Internet content. According to a Treasury Department news release, “CEIEC provided Venezuela . . . a commercialized version of China’s ‘Great Firewall.’” US persons have until 14 January 2021 to wind down transactions with CEIEC under General License 38.
  3. US Customs and Border Protection (CBP) unveiled a Withhold Release Order (WRO) on cotton and cotton products from Xinjiang Production and Construction Corps (XPCC) imported into the United States, based on reports of XPCC’s use of forced labor. As explained in a CBP news release, CBP can release a shipment held under a WRO if an importer proves it “was not produced with forced labor.”
  4. OFAC sanctioned an individual in Mexico under the Foreign Narcotics Kingpin Designation Act (FNKDA) for acting on behalf of a prominent narcotics trafficker in Mexico accused of orchestrating the murder of a US Drug Enforcement Administration (DEA) agent in 1985. Separately, OFAC sanctioned one individual, three of his associates, and four related companies under the FNKDA for supporting the Clan del Golfo in Colombia.
  5. OFAC named the Kaniyat militia in Libya and its leader as SDNs under the Global Magnitsky Sanctions program (Executive Order 13818). According to a Treasury Department news release, the militia is “responsible for the murder . . . as well as torture, forced disappearances, and displacement of civilians” in Libya.




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

Nicholas Turner

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