Sanctions Top-5 for the week ending 5 March 2021

Here are five things that happened this week in the world of economic sanctions that I think you should know about.

Sign up here if you would like to receive these summaries by email. Click here for an index of past Sanctions Top-5 briefings.

  1. The Biden administration unveiled a range of sanctions and export control measures in response to Russia’s suspected poisoning of opposition figure Alexei Navalny and his subsequent arrest and imprisonment. The US Office of Foreign Assets Control (OFAC) and the State Department named several Russian officials and entities as Specially Designated Nationals (SDNs). The US Commerce Department’s Bureau of Industry and Security (BIS) added several entities to the Entity List. As explained in a fact sheet, the State Department also announced an expansion of restrictions on Russia introduced in 2018 under the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 and identified six entities as operating in the Russian Defense and Intelligence Sectors — persons who engage in significant transactions with them could face secondary sanctions under Section 231 of the Countering America’s Adversaries Through Sanctions Act (CAATSA).


Myanmar’s MEC and MEHL, the country’s premier military controlled conglomerates, were conspicuously not sanctioned by OFAC following last month’s coup. Instead OFAC named three lesser known subsidiaries as SDNs under the newly issued Executive Order 14014. Following those designations, the Myanmar military continued its violent crackdown on protesters, leading OFAC to sanction two additional military officers. It lacks the oomph of the SDN List, but BIS’s addition of MEC and MEHL to the Entity List could signal the Biden administration’s willingness to ratchet up sanctions in response to developments on the ground, with more to come.

What about EU sanctions? According to Reuters, the EU is reportedly preparing a Myanmar sanctions package that could include sanctions on MEC and MEHL, among others, later this month. For their part, Myanmar’s new leaders are reportedly saying they won’t be deterred by outside economic pressure.

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.)



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

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