Sanctions Advising

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GTAC Experts are former Regional Export Control Officers (ECOs) for the Bureau of Industry and Security (BIS) responsible for assisting companies throughout the world comply with sanctions and trade restrictions in exporting U.S. origin commodities to Russia, Iran, China and other parts of the world. We are multi-lingual and have assisted many companies, trade associations, and foreign governments in facilitating secure international trade. Let GTAC’s U.S. government-trained, experienced and internationally respected staff assist your company with your trade compliance needs. Contact us for more information.


Sanctions by the Numbers: 2021 Year in Review (CNAS)

The first year of President Joe Biden’s administration witnessed major developments in U.S. sanctions strategy, including a general review of all sanctions programs under the auspices of the U.S. Department of the Treasury. Most notably, the Treasury has revised and expanded its sanctioning authorities to align with the broader foreign policy objectives of the Biden administration and to respond to global developments, such as by reactivating its country-specific program on Burma, issuing licenses for counterterrorism sanctions against the Taliban, creating new sanctions programs on Ethiopia, establishing the United States Council on Transnational Organized Crime, terminating its program on Burundi, revoking terrorist designations on the Revolutionary Armed Forces of Colombia (FARC) and the Ansarallah (Houthis), and issuing the first-ever virtual currency–related designation on a Russian cryptocurrency exchange for facilitating financial transactions linked to ransomware. Additionally, the Biden administration decided to waive sanctions related to the Nord Stream 2 project, a 1,200 kilometer-long natural gas pipeline running from northern Russia to Europe across the Baltic Sea, which continues to generate significant controversy in Congress.

The Biden administration has demonstrated its intent to continue using sanctions within its foreign policy toolkit to combat illicit activity that threatens both national security and the security of U.S. allies and partners. In 2021, the Treasury issued a total of 765 new designations with the majority (51 percent) pursuant to country-specific sanctions programs, mainly Belarus, Burma, China, and Russia, and 787 delistings with roughly 92 percent pursuant to thematic sanctions programs, mainly addressing drug trafficking. Coordination with allies—especially the European Union, United Kingdom, and Canada—to address human rights abuses abroad was a recurring theme in a large number of sanctions designations for both country-specific and thematic sanctions programs. In tandem with allies during the Summit for Democracy and International Human Rights Day in early December, the United States levied 45 new designations to address human rights abuses and their facilitators across the world, including in countries such as China, Burma, Russia, North Korea, and Bangladesh. These multilateral efforts contrast to the previous administration, which mainly used unilateral sanctions to support its “maximum pressure” sanctions campaign against key country targets like Venezuala, North Korea, and Iran. This suggests that the Biden administration seeks to take a more cautious approach toward leading foreign policy strategy with the use of sanctions.

This CNAS edition of Sanctions by the Numbers provides a snapshot of overall sanctioning trends, an overview of the most heavily used country-specific and thematic sanctions programs, and the global distribution of sanctions designations during the first year of the Biden administration.

China-related Sanctions (Excerpt)
In addition to the 70 designations pursuant to the country-specific sanctions program on China (CMIC), the Treasury imposed 30 designations on China-related targets under various other sanctions programs. To address continued human right abuses in Xinjiang against the Muslim Uyghurs, the Treasury—along with
Canada, the EU, and UKsanctioned two Chinese government officials, Wang Junzheng and Chen Mingguo, pursuant to human rights–related authorities. OFAC also imposed seven Hong Kong–related designations pursuant to Executive Order 13936, which addresses the oppressive actions of the Chinese government and Hong Kong authorities against democratic protests linked to Beijing’s Hong Kong National Security Law. The remaining sanctions on China and Hong Kong–related targets are pursuant to GLOMAG, SDGT, ISFR, DPRK3, and ILLICIT-DRUGS-EO for providing designated terrorist groups, such as the IRGC-QF and Hezbollah, with financial assistance and money laundering services.

Russia-related Sanctions (Excerpt)
The Treasury imposed the largest number of sanction designations on Russia-related individuals and entities (95) in response to Moscow poisoning anti-corruption and political activist Alexei Navalny, attempting to influence the U.S. election, authorizing the illegal occupation of Crimea, developing chemical weapon capabilities, and conducting malicious cyber activities against the United States and its allies. After consulting with European allies, the Treasury imposed its first round of sanctions in March 2021 on seven Russian government officials and three government research institutes in connection with the poisoning of Navalny. Later that year, the Treasury imposed additional sanctions against associated Russian targets alongside the European Union (EU). In April, the Treasury continued to coordinate with allies through joint sanctioning efforts involving the EU, the UK, Canada, and Australia, and imposed a total of 32 sanction designations against Russian government officials responsible for the occupation of Crimea. Beyond targeting government officials involved in the occupation, these designations also included individuals and construction companies involved in creating the Kerch Strait Bridge to connect mainland Russia to Crimea, which hastened the occupation process. The Treasury issued its first-ever designation on a virtual currency exchange, SUEX, based in Russia for facilitating transactions related to ransomware payments. In addition to this designation, the Treasury also imposed CYBER2 sanctions on two ransomware operators, Ukrainian national Yaroslav Vasinskyi and Russian national Yevgeniy Polyanin, for their involvement in ransomware attacks against nine U.S. companies, including the July 2021 Kaseya ransomware attack. As previously mentioned, the Treasury has issued 35 PEESA-related sanctions designations on Russian targets involved in threatening European energy security.