New Year, New Administration, New Sanctions

The start of 2021 brought a flurry of activity in export compliance, including a number of actions related to denied party screening.

Following December's publication and expansion of sanctions lists largely targeting Chinese entities, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a rule (86 FR 3793), effective January 15th, creating the Hong Kong-Related Sanctions Regulations.  This is the latest step in a series of actions following Hong Kong’s loss of autonomy in 2020.  OFAC typically issues separate, but similar, sanctions regulations to implement country-specific sanctions.  Persons subject to the Hong Kong-Related Sanctions Regulations were already listed and will continue to be added to OFAC's Specially Designated Nationals and Blocked Persons List (SDN List).

In another developing story, OFAC has added individuals and entities to the SDN list under an executive order issued on February 11, "Blocking Property With Respect To The Situation In Burma."  The Commerce Department is considering additional sanctions, including "possible Entity List additions, adding Burma to the list of countries subject to the EAR’s military end use and end user (MEU) and military intelligence end use and end user (MIEU) restrictions, and downgrading Burma’s Country Group status in the EAR."

These are just highlights of the ongoing changes to the SDN List and other screening lists.  Ongoing screening against updated lists is a must-do for export compliance.