These designations have presented practical challenges for multinational businesses, including companies with long supply chain networks, as well as businesses that conduct business in Hong Kong. persons that engage in material transactions with the designated parties are at risk of being targeted by U.S. persons are prohibited from engaging in transactions with the designated parties and their majority-owned subsidiaries and (2) non-U.S. Similarly, pursuant to the Autonomy Act, OFAC designated several key Chinese Communist Party members within the Hong Kong government, including Carrie Lam, the chief executive of the Hong Kong Special Administrative Region.Īs a result, (1) U.S. For example, pursuant to the Uyghur Human Rights Policy Act, OFAC designated Xinjiang Production and Construction Corps, a state-owned economic and paramilitary organization, to the Specially Designated Nationals and Blocked Persons, or SDN, list. In succeeding months, OFAC exercised these new authorities. financial institutions that knowingly conduct significant transactions with parties sanctioned pursuant to the Autonomy Act. Enacted in July, the Hong Kong Autonomy Act authorizes the imposition of sanctions against (1) persons who materially contribute to China's efforts to undermine Hong Kong's autonomy and (2) non-U.S.person determined to be contributing to mistreatment of Uighurs or other minority groups in the Xinjiang Uighur Autonomous Region. government to impose sanctions against any non-U.S. Enacted in June, the Uyghur Human Rights Policy Act authorizes the U.S.passed bipartisan legislation authorizing OFAC to impose sanctions against Chinese and non-Chinese parties engaged in specified activities supported by the Chinese government: government expanded its coordinated effort to curtail China's growing influence and deter perceived malfeasance through the introduction of new sanctions authorities. and China have created various complications for multinational companies, including increased tariffs, new export controls, and heightened scrutiny of cross-border investments. Over the past four years, escalating tensions between the U.S.

While new sanctions targeting China, with good reason, have commanded extensive domestic and international attention, the Trump administration also continued to leverage existing sanctions authorities to squeeze unfriendly regimes in Iran and Venezuela, with potential implications for an incoming Biden administration.Īnd although enforcement activity by the Office of Foreign Assets Control declined, published enforcement actions identify key risk areas as OFAC continues to focus its attention on sanctions compliance by nonfinancial institutions. continued to expand the use of economic sanctions in an aggressive and, in some cases, unconventional manner in pursuit of U.S.

18, 2020.ĭespite a global pandemic, throughout 2020, the U.S. This article was originally published by Law360 on Dec.

Ofac iran sanctions summary