Sanctions Top-5 for the week ending 9 April 2021

  1. The White House announced the revocation of Executive Order 13928 authorizing blocking sanctions in relation to the International Criminal Court (ICC) and the lifting of sanctions on the ICC’s chief prosecutor and another official, who were named as Specially Designated Nationals (SDNs) in September 2020. According to a State Department announcement, the Biden administration determined the Trump-era measures “were inappropriate and ineffective.”
  2. The US Office of Foreign Assets Control (OFAC) named state-owned Myanma Gems Enterprise as an SDN under Executive Order 14014. According to an OFAC news release, the company “is responsible for all gemstone activities in Burma.” (In case you missed it: here is a recording of last week’s webinar hosted by featuring Dr. Rocco Macchiavello of the London School of Economics and me in a talk about Myanmar’s economy and the potential impact of new sanctions.)
  3. The US Commerce Department’s Bureau of Industry and Security (BIS) added seven Chinese companies to the Entity List under the Export Administration Regulations (EAR) for their roles in “building supercomputers used by China’s military actors” and other activities. As a result, a BIS license is now required for export, re-exports, and in-country transfers of all items subject to the EAR involving the companies.
  4. The US Department of Justice (DOJ) announced the arrest and indictment of an individual in New York accused of selling more than USD 350,000 in cosmetics to an Iranian importer via the United Arab Emirates in violation of US sanctions. Talk about a cover up!
  5. OFAC issued two FAQs (here and here) clarifying that (generally speaking) both US and non-US persons who engage in permissible humanitarian-related transactions in Syria will not be subject to US sanctions risks, including secondary sanctions under the Caesar Syria Civilian Protection Act. According to FAQ 885, “OFAC remains committed to ensuring that humanitarian assistance can flow to the people of Syria and maintains a favorable policy supporting the provision of humanitarian assistance.”




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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: