Sanctions Top-5 for the week ending 8 May 2020

  1. The US Office of Foreign Assets Control (OFAC) announced a USD 257,862 settlement with a Kansas-based company for violations of the Cuban Assets Control Regulations (CACR). According to the OFAC enforcement release, the company sold agricultural products to a Cuban customer via its non-US affiliates without authorization under a general or specific license. (More on the case below.)
  2. Here comes Congress. Senate Majority Leader Mitch McConnell said the US Congress could soon pass a bill directing the Trump administration to adopt targeted sanctions against Chinese officials responsible for human rights abuses in the Xinjiang Uighur Autonomous Region (XUAR). The bill also calls for export controls on US-origin items that could be used in China to “suppress individual privacy, freedom of movement, and other basic human rights.” Versions of the Uyghur Human Rights Policy Act were previously approved by the House of Representatives and the Senate in 2019.
  3. Meanwhile, Senator Tom Cotton introduced the Li Wenliang Global Public Health Accountability Act of 2020 to authorize sanctions in connection with “deliberate concealment or distortion of information about public health emergencies of international concern.”
  4. OFAC made administrative updates to 11 entries on the List of Specially Designated Nationals and Blocked Persons (the SDN List) to change their “aliases” to “weak aliases.” This seems like a small thing, but for people who have to review all of those name screening hits, it can make a big difference. As explained in FAQ 124, “OFAC does not expect that persons will screen for weak AKAs.”
  5. The Financial Action Task Force (FATF) and the Middle East and North African Financial Action Task Force (MENAFATF) published their mutual evaluation report on the United Arab Emirates (UAE). Among other findings, the report highlights deficiencies in handling targeted financial sanctions (TFS), despite the UAE’s elevated sanctions risk profile. For example, according to the report, many regulated entities “are not aware of the requirement to immediately freeze funds and assets in case of exact match with sanction lists.

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