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ARTICLE · 11 MARCH 2020

Four Things We Learned From OFAC's Recent SDN Designations

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Recent actions taken by the US Office of Foreign Assets Control (OFAC) in imposing, then lifting, sanctions on major multinational companies provide important new lessons for their counterparties.

United StatesInternational Law
Wendy Wysong
Wendy Wysong
Ali Burney
Ali Burney
Nicholas Turner
Nicholas Turner
Hena Schommer
Hena Schommer

Recent actions taken by the US Office of Foreign Assets Control (OFAC) in imposing, then lifting, sanctions on major multinational companies provide important new lessons for their counterparties.

Take, for example, OFAC's January 31, 2020 lifting of sanctions on China-based COSCO Shipping Tanker (Dalian) Co., Ltd. (COSCO Dalian), five affiliates, and one individual, previously named as Specially Designated Nationals (SDNs) in September 2019 for knowingly engaging in a significant transaction for the transport of oil from Iran.

COSCO Dalian, a subsidiary of China Ocean Shipping Company (COSCO), the world's third-largest shipping company, is just one of several major names designated by OFAC as SDNs over the past two years for running afoul of US foreign policy goals. Others include Rosneft Trading S.A. (Rosneft Trading), which was designated in February 2020. They are unlikely to be the last.

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