Sanctions Top-5 for the week ending 5 June 2020

  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.




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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: