Secondary Sanctions Enforcement Announcement - Feb. 14, 2020 Imposition of Nonproliferation Measures Against Foreign Persons (Pursuant to INKSNA)

Date issued: Feb. 14 2020

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TURBOFAC Commentary (521 words)

Notes:

1) This FR notice announces "secondary sanctions" against a handful of Turkish, Chinese and Russian persons pursuant to the INKSNA, a "secondary sanctions" statute that is often overlooked because it is seldom invoked and does not include any OFAC-administered sanctions provisions, e.g. blocking. Here, sanctions were all imposed on persons that had not previously been subject to sanctions. None of those on whom sanctions were imposed were, concurrent with this action by the Department of State, made subject to any OFAC-administered sanctions authority. See the Department of State press release announcing these actions at https://www.state.gov/new-sanctions-under-the-iran-north-korea-and-syria-nonproliferation-act-inksna/.

The announcement is worth taking note of in light of the fact that, at the time it was made, the activities deemed sanctionable appeared to be within the scope of several Iran-specific, OFAC-administered secondary sanctions authorities. According to the announcement, most of the...