Sanctions Top-5 for the week ending 5 June 2020

Nicholas Turner
3 min readJun 9, 2020


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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  1. The Office of Foreign Assets Control (OFAC) named four companies based in the Marshall Islands and Greece and four of their vessels as Specially Designated Nationals (SDNs) under Executive Order 13850 for transporting oil from Venezuela. The designations follow the release of the US government’s “Guidance to Address Illicit Shipping and Sanctions Evasion Practices” about two weeks before.
  2. OFAC published four new FAQs clarifying the scope of Executive Order 13902 of 10 January 2020, “Imposing Sanctions With Respect to Additional Sectors of Iran.” FAQ 830 states that secondary sanctions will not apply to certain humanitarian-related activities in Iran. The other FAQs provide guidance on how secondary sanctions under Executive Order 13902 may apply to certain activities in the construction, mining, manufacturing, and textiles sectors of the Iranian economy.
  3. The US State Department announced the addition of seven entities to the List of Restricted Entities and Subentities Associated with Cuba (a.k.a. the Cuba Restricted List). They include a military-controlled financial institution (Fincimex) and three hotels, two scuba diving centers, and a marine park owned by the Cuban military.
  4. In related news, Reuters reported that US-based Marriott International will be forced to close its Four Points by Sheraton hotel in Cuba by the end of August after the US Treasury Department declined to renew a specific license issued under the Obama administration. The property is currently cerrado, according to Marriott’s website.
  5. The Senate Committee on Banking, Housing, and Urban Affairs held a hearing entitled “Crisis in Hong Kong: A Review of US Policy Tools” featuring Peter Harrell of the Center for a New American Security (CNAS) and other noteworthy experts. (Find the statements and testimonies here.) Meanwhile, Secretary of State Mike Pompeo gave an interview to the Daily Caller and talked about Hong Kong.


It’s been almost two weeks since Secretary Pompeo’s announcement that he could not certify that Hong Kong continues to warrant differential treatment under US law, per the Hong Kong Policy Act (as amended by last year’s Hong Kong Human Rights and Democracy Act). How are people here responding? If this were a typhoon, I would say it’s about a Number 1. Windy, but calm. The American Chamber of Commerce in Hong Kong released a survey of its members showing that about 75 percent of respondents are taking a wait-and-see approach to the current situation. About 70 percent have no plans to move capital, assets, or operations from Hong Kong at this time.

Are sanctions imminent? The Daily Caller interview is a bit out there, but Secretary Pompeo managed to stay on message. First, he said “we have an obligation . . . to work diplomatically with the Chinese Communist Party.” (That’s a relief.) Second, he made it clear that the US response will be based on Beijing’s handling of the national security law and Hong Kong elections in September. He made the same points at the American Enterprise Institute the week before. Still too early to board up the windows, if you ask me.

If you tuned in to last week’s session at ACAMS24+ with ANZ’s Kylie Oliver and me, you heard about the intersections of trade-based money laundering and sanctions. Next week, check out the Asia-focused webinar on “Finding the Bad Actors in Trade Finance” featuring Windward’s Ron Crean, Pelican’s Colin Camp, Acuris’ Nick Parfitt, and Deloitte’s Radish Singh, on 17 June at 3:00 p.m. Hong Kong time. Registration is available here.

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.)



Nicholas Turner

US attorney in Hong Kong specializing in economic sanctions, financial crimes. This is an archive of briefings published between 2017 and 2022.