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Last week's major developments in sanctions - Mar. 22nd to Mar. 26th, 2021

Monday, March 22nd

- In a concerted move the United States, the United Kingdom, the European Union, and Canada, imposed a number of restrictions against former and incumbent Chinese officials in Xinjiang region.

In particular:

  • OFAC added two individuals to its SDN list under the Global Magnitsky program. (Here) (Department of State's press release) OFAC had already added several individuals and entities in Xinjiang region. (First round)(Second round)

  • OFSI added four individuals and one entity to its list of sanctions targets. (Here)

  • The European Union added the same four individuals and the same entity to its Global Human Right Sanctions regime targets. The new sanctions entails financial sanctions (asset freezing) and travel bans. (Here)

  • Canada also added the same four individuals and the same entity. (Here)

- There were also additions to the sanctions lists related to Burma (Myanmar) by both the U.S. and the EU.

  • OFAC added two individuals and two entities in Burma who are involved in cracking down on the protestors in the country. (Here) (Department of State's press release)

  • EU added 11 individuals to its Myanmar Sanctions Regime. (Here) An interesting point about these designations was that everyone knew that they were coming. (Here) Assuming one criteria for effectiveness of sanctions is gaining some leverage over an actor following the blocking of its funds/economic resources, such pre-announcements, in turn, raises questions about the effectiveness of blocking sanctions. What would you do if you knew that next week the EU would add your name to its sanctions list? Probably you would move all you had in the EU, wouldn't you?

- EU also added the following individuals and entities to its list of sanctions targets under the Global Human Rights Sanctions Regime. (Here)

  • In North Korea: the Minister of State Security, the Minister of Social Security, and the Central Public Prosecutor’s Office

  • In Libya: the Head and a key member of the Kaniyat Militia of Libya as well as the Militia Group itself

  • In Russia: the Head of Department of the Ministry of Internal Affairs of the Russian Federation in the city of Argun in the Chechen Republic, the Deputy Prime Minister of the Chechen Republic

  • In South Sudan: a Major General of the South Sudan People’s Defense Forces

  • In Eritrea: the National Security Office (a.k.a. National Security Agency) of the Government

- OFAC announced a settlement with UniControl Inc., a U.S. company whose European trade partners reexported its products to Iran. UniControl had actual knowledge that its products were ending up in Iran and it only stopped shipping goods to its European trade partners after 19 shipments. (Here)

- The United States Department of Justice announced the first extradition of a North Korean national to the United State. The defendant faces money laundering charges. (Here)

- Check out the joint report of the High Representative and the Commission regarding EU-Turkey relationships which suggest expansion of sanctions against Turkey "[s]hould Turkey, [...] , not move forward constructively in developing a genuine partnership with the EU." Yet, there was no mention of additional sanctions against Turkey in the statement of the member of the European Council. (Here)

Tuesday, March 23rd - France added ten names to its national asset freeze list under France terrorism-related sanctions authority. (Here)

Wednesday, March 24th

- No major development on this day.

Thursday, March 25th

- France added two names to its national asset freeze list under France terrorism-related sanctions authority. (Here)

- OFSI added another Burmese entity, Myanmar Economic Holdings Public Company LTD, to the list of those subject to sanctions. (Here)

- OFAC added two Burmese entities to the Treasury SDN list. OFAC concurrently issued four General Licenses, one for winding up the activities with the two recently listed entities and 3 related to the official business of the U.S. Government, NGOs, and activities of certain international organizations respectively with those recently listed entities. (Here and Department of State'd press release)

Friday, March 26th

- EU delisted an individual who used to be sanctioned as part of the EU Libya sanctions regime. (Here)

-OFAC announced a settlement with Nordgas, S.r.l, an Italian company for apparent violations of the Iranian Transactions and Sanctions Regulations. The latter reexported U.S. origin goods to Iran by deceiving its the U.S. manufacturers regarding the end-user of the goods. It is the second settlement notice in row in which someone had asked a U.S. manufacturer to remove "Made in U.S.A." label. (Here)

Recommendations of the week

- This week I would like to recommend a truly impressive work done by NYT on sanctions evasion technics used to export oil to North Korea. (Here)


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