On April 28, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) took a series of Iran-related actions as part of the Administration’s “Economic Fury” campaign of exerting maximum pressure against Iran. Specifically, OFAC (1) issued an alert warning of the sanctions risks of dealing with Chinese “teapot” oil refineries that process Iranian crude oil and (2) published FAQ 1249, which warns that “toll” payments to the Government of Iran (“GoI”)…
Hong Kong controls dual-use items under the Import and Export Ordinance (Cap. 60) and its corresponding subsidiary legislation, the Import and Export (Strategic Commodities) Regulations (Cap. 60G) (“IESCR”). On 17 September 2021, an order to amend the list of strategic commodities under relevant schedules to the IESCR came into effect. The amendments aim to align Hong Kong’s control list with international non-proliferation regimes, including the Wassenaar Arrangement. The Trade and Industry Department has provided guidance…
On June 3, 2021, President Biden issued Executive Order 14032, “Addressing the Threat from Securities Investments that Finance Certain Companies of the People’s Republic of China” (the “CMIC EO”). This amends and replaces Executive Order 13959 (“EO 13959”) and revokes Executive Order 13974 (“EO 13974”) that restricted investments in certain “Communist Chinese Military Companies” (“CCMCs”). The main changes implemented by the CMIC EO and related public guidance are to (1) change the group of targeted…
Effective March 22, 2021, Canada has imposed new sanctions against four Chinese officials and a Chinese entity under the newly enacted Special Economic Measures (People’s Republic of China) Regulations (the “Regulations”), in response to the alleged human rights situation in Xinjiang. Becoming a listed person under the Regulations has two noteworthy consequences. First, listed persons who are individuals are considered inadmissible to Canada under the Immigration and Refugee Protection Act. Second, the Regulations effectively impose…