Geopolitical Tensions & Economic Warfare Sanctions in 2023

Geopolitical
Tensions &
Economic
Warfare
Sanctions in 2023
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Geopolitical Tensions & Economic Warfare Sanctions in 2023
compliancevision.com
Contents
03 Sanctions & Summary
Part 1: Global political instability Part 2: Global trends, regional impacts
05 Russia 23 China & North Korea
17 The US Sanctions Regime 37 Europe
21 Sanctions response 39 Asia, Africa & “Americas”
01 02
Summary
In 2022, the unprecedented scale of sanctions defined and shaped the world.
This section looks at the prospects for Russia and Ukraine in the year ahead,
simmering US-China tensions, and why we should expect the return of familiar
hotspots, including Iran and North Korea. The full-scale Russian invasion
of Ukraine began in February 2022. It accelerated pre-existing trends in

economic statecraft, with a coalition of democratic countries imposing massive,
coordinated sanctions against the Putin regime. This Ukrainian ‘playbook’
Sanctions on sanctions could be used again in similar crises.
As we entered 2023, geopolitical tensions between increasingly polarized camps

Sanctions are restrictive measures international organizations
of authoritarian regimes and a coalition of Western-democratic countries
and national governments apply to influence or punish other
(primarily the US, Canada, EU, UK, Japan, Australia, and several other European
states and non-state actors, such as terrorists or organized and Asia-Pacific jurisdictions) were expected to dominate, with economic
criminals. They are typically used to support international peace, statecraft playing a significant role in the West’s approach to the contest.
stability, and national security goals, but not exclusively.
Shockingly, this prediction was proven correct, and sanctions against Russia
Nearly all countries follow the sanctions imposed by the UNSC,
remain and are likely to tighten further in 2023. Meanwhile, tensions between
but an increasing number have their autonomous regimes,
Western countries, Iran, and North Korea have remained high.
of which the US is the most influential. Sanctions commonly The revival of the Iran nuclear deal now looks unlikely, and Pyongyang has
target entities such as official institutions, businesses, groups, caused consternation with numerous missile tests.
networks, and individuals. When imposing sanctions,

sanctioning bodies commonly prohibit those under their Consequently, we expect further sanctions, but these will not come from the UN
authority from undertaking economic and financial interactions Security Council (UNSC) as before, with Russia and China blocking action
with the target or freeze the target’s accessible assets. Individual initiated by the US, France, and the UK, the Council’s permanent Western
sanctions also now typically involve travel bans to areas under members. Any further measures on weapons proliferation in 2023 will likely come
the sanctioning body’s control or via carriers under its authority. from the US and its allies alone. The final headline challenge is China, on which
Western countries have imposed various sanctions for human rights abuses and
domestic repression. Compared to recent years, 2022 has been relatively quiet,
although the US has kept the pressure on the Chinese technology sector.
There was also a brief flare-up in August over the status of Taiwan between
the US and China, which, while self-governing, is seen as a part of China by

Beijing. Although neither the US nor China is likely to stimulate a further crisis
in 2023, one cannot be ruled out, with any Chinese attempt to intimidate Taiwan
through military means leading to a similar Western sanctions response to that
seen against Russia.
03 04
Russia’s military aggression in Ukraine

The Western democratic coalition responded to Russia’s Special Military Operation (SMO)
in Ukraine with sanctions targeting official institutions, businesses, groups, networks,

individuals, and travel bans. Consequently, Russia was the top geopolitical hotspot firms were
most concerned about this year.
Nearly all countries abide by the sanctions imposed by the United Nations Security Council
(UNSC), but an increasing number of nations have implemented their own autonomous
regimes, with the United States being the most influential. Such sanctions target entities such
as official institutions, businesses, groups, networks, and individuals. When enforcing
sanctions, sanctioning bodies commonly prohibit those under their authority from engaging
in any economic or financial activities with the target while also freezing all accessible assets.
Sanctions can also now involve travel bans to areas under the sanctioning body’s control
or via carriers under its authority.
To learn more about this, please see our report on ‘Geopolitics of Regulatory Compliance.’
In times of heightened international tension, the use of coordinated sanctions by the Western
democratic coalition is highly likely, as the current Russia-Ukraine conflict has proven.
Unsurprisingly, this has caused Russia to be the foremost concern for firms regarding
geopolitical hotspots this year.
05 06
Western allies' common response

The escalation between the US Before the invasion of February 2022,
and Russia Western countries had imposed a variety
of sanctions on Russia due to its violations
of human rights, corruption, political
For the past decade, Russia,
This dispute has led to several
interference, cyber-attacks, and military
the United States, and their flare-ups throughout the decade,
aggression.
respective allies have been most notably with the illegal

escalating confrontations. annexation of Crimea in March
The US had the most extensive sanctions,
President Vladimir Putin has 2014 and the Russian-supported
targeting oligarchs close to President
accused Western nations
proxy war in eastern Ukraine.
Putin, politicians, military officers,
of attempting to encircle Russia

the Russian military and energy sectors,
and discredit him, while
At the end of 2021, tensions
and those responsible for abuses
the democratic world has increased again as Putin voiced

and corruption, such as Sergei Magnitsky.
reprimanded Putin for his regime's his displeasure with Ukraine's

In response to the invasion, the US
mistreatment of domestic move toward the West and
imposed further measures. Many other
dissidents, such as Alexei Navalny, increased military presence
countries joined them, including the EU,

attacks on those living overseas, at the Ukrainian border.
Norway, Switzerland, Iceland, the UK,

interference in Western politics, Despite the predictions
Canada, Australia, New Zealand, Japan,

and military expansionism.
of Westerners that Russia would
South Korea, Singapore, and Taiwan.
The most significant point
not take drastic action, Putin
Several countries - including Switzerland
of contention, however, has been officially recognized
- imposed autonomous sanctions for
Ukraine. Putin considers

the independence of the
the first time. The most significant

the country to be within Russia's rebel-controlled regions
sanctions were imposed in the first few

sphere of influence, thus in Donetsk and Luhansk
months after the invasion, but new

preventing Ukraine from joining on February 21, 2022, followed by
packages have been introduced across

the European Union or NATO. a full-scale invasion on February
the year; as of the time of writing, the EU
24, 2022, known as the 'special
has put its eighth round of restrictive
military operation.’
measures in place.
07 08
The countries involved have all implemented different measures,

On March 8, the US prohibited the import of Russian oil, gas, LNG,
but their responses have been highly coordinated and similar.

and coal into the US, while the EU and UK have taken steps to phase out
Key objectives of their democratic efforts have included the imposition the import of Russian oil, refined oil products, and coal. Germany has
of individual sanctions - such as personal asset freezes and travel bans suspended the opening of the Nord Stream 2 gas pipeline between
- on prominent figures within the Russian political and military elite, Russia and Germany indefinitely. Nevertheless, a full ban on gas has yet
including President Putin, Foreign Minister Sergei Lavrov, and members to occur, with the EU only committing to reduce reliance on Russian
of the Duma, as well as those responsible for atrocities in Ukraine. fossil fuels, like gas, by 2027.
Financial sanctions have also been imposed, such as asset freezes
and transactional bans on the Central Bank of Russia, its National Moreover, the US and UK imposed sanctions in May and the EU in June
Wealth Fund, and the Ministry of Finance, to prevent the Russian on providing corporate and professional services to individuals
government from using foreign currency reserves or selling assets

in Russia. To enhance the effectiveness of sanctions, the G7 countries
to fund the war.
and the EU (joined by Australia) established the Russian Elites, Proxies,

and Oligarchs (REPO) Task Force on February 26, meant to identify
Furthermore, several major Russian financial institutions, including and freeze the assets of specific sanctioned individuals and Companies.
Sberbank, have been removed from the SWIFT messaging system, The US Department of Justice (DoJ) also formed the Task Force Klepto
while the US has designated Crypto Asset Service Providers (CASPs) Capture, and the UK's National Crime Agency (NCA) created the
and individual wallets used for suspected sanctions evasion and Combating Kleptocracy Cell.
fundraising.
The REPO Task Force has played an essential role in fostering

In October, Singapore cautioned its CASP sector to abide by Russian discussions around these legal challenges, focusing on how frozen
sanctions, particularly in cases where people were attempting
Russian assets can be seized by sanctioning authorities and used
to generate funds to back the Russian war effort by means

to help rebuild Ukraine. This involves looking at pragmatic precedents
of cryptocurrency.
based on existing fraud, money laundering, and sanctions legislation

and seeking to provide a surer legal footing in the future by adding
targeted Sanctions
sanctions evasion to the RICO Act.
Finally, the European Commission and the Canadian government have

Western allies have included a variety of export and import restrictions
proposed different legislation to provide a legal basis for asset recovery.
on Russian industries and firms involved in the production
The European Commission's proposed Directive of Asset Recovery and

or procurement of weapons, dual-use goods, advanced technology,
Confiscation offers to make sanctions evasion an offense, while
iron and steel, logistics and transport, and the energy sector.
the Canadian government's Frozen Assets Repurposing Act would allow
the seizure of assets from individuals deemed a risk to international

security.
09 10
compliancevision.com Geopolitical Tensions & Economic Warfare Sanctions in 2023
Russian response to the West

In response to Western sanctions, the Russian rhetoric has been fierce. In
March, President Putin labeled them as an "economic war." However, Russia's
Russian sanctions impact on Western economies
own countersanctions have been much less sweeping, with only targeted The impact of Western sanctions on Russia has been undeniable, as the
sanctions on leading US and other Western politicians, as well as restrictions country's economy has gone through a severe contraction, and restrictions on
on foreign currency transactions and debt repayments by foreign businesses supply have hindered the performance of the Russian military. However,
and designating sanctioning countries as ‘unfriendly.’
sanctions still need to achieve their goal of persuading President Putin to

Additionally, Russia has used Europe's reliance on gas to its advantage while withdraw from Ukraine completely. Putin has historically been resilient
not cutting off supply entirely. September saw Putin's spokesman, Dmitry regarding economic hardship and willing to accept the costs of sanctions if it
Peskov, state the pipeline would not be re-opened until the “collective West” does not lead to political unrest. In addition, it has become clear that
had removed its sanctions. Furthermore, President Putin announced that sanctions could be more effective due to various vulnerabilities in the Western
buyers would need to pay for gas in a scheme involving an initial payment in sanction regime. These include gaps in sector coverage, such as the lack of
an international currency such as Euros or US dollars, followed by conversion an EU ban on the import of Russian natural gas and exemptions and gradual
into Roubles.
introductions of sanctions that have allowed Russian individuals and

companies to take action to change ownership structures.
This puts European buyers in a tough spot, as it risks them breaching The role of neutral countries has been significant in providing alternative
sanctions due to Russia’s Central Bank’s role in converting currencies. As a markets for Russia, thereby allowing it to re-direct its oil exports away from
result, the EU has primarily bowed to Russian demands while advising buyers Europe. India, for example, has stipulated that it will only follow UNSC
to issue statements that deem the initial payment the completion of the measures, while the UAE has become a new safe haven for Russian oligarchs.
transaction. Lastly, Russia has used a blockade of Ukrainian wheat, corn, and This has benefited Russia, as major economies such as China and India have
other cereal exports from Ukraine's Black Sea ports intermittently to cause been willing to purchase its oil at discounted prices of around $30 per barrel.
global food price hikes. This was temporarily resolved in July with a deal This has enabled Russia to continue its oil exports despite the international
brokered by Turkey, but Russia withdrew in October in response to Ukrainian sanctions.
drone attacks.
As of year-end, the deal has remained in place, yet Russia has re-asserted its
right to withdraw, creating the possibility of future global food security issues.
11 12
There is ample evidence that Russian individuals, businesses, and other entities have
been able to circumvent Western sanctions by utilizing various strategies.
As predicted at the start of the war, Russian
These tactics include procuring goods through proxies, obfuscating the Russian origin citizens have demonstrated a willingness
of banned commodities, and using neutral countries as conduits for ‘origin laundering.’ to utilize cryptocurrency, particularly
For instance, the US Treasury’s Office for Foreign Asset Control (OFAC) identified
stablecoins, as a store of value and form
and designated a network centered on the Moscow-based Serniya Engineering, which of exchange in 2022. This is especially true for
involved clandestine procurement through companies in Spain, the UK, and Singapore. those specifically targeted by sanctions,
Similarly, OFAC designated a further network linked to businesses based in Germany as there have been indications that they have
and the UAE.
sought out crypto to circumvent Western

measures. In July of the same year, the UK's
Additionally, Russia has re-registered oil tankers to ‘flags of convenience’ and blended Joint Money Laundering Intelligence Taskforce
its own oil with other nations’ supplies to evade commodity bans. Moreover, there is (JMLIT) issued an alert warning of designated
evidence that Russia is exploiting neutral countries to ‘origin launder’ commodities. individuals exploring the use of cryptocurrency
Gold exports from the UAE to Switzerland rose to 36 tons in the month following the to evade sanctions. Nevertheless, assessments
Russian invasion of Crimea.
from crypto analytic firms such as Chainalysis

and US officials have revealed that the
In the wake of sanctions imposed in 2022, Russian oligarchs and businesses have cryptocurrency market is not liquid enough
employed various tactics to circumvent these measures. These have included to support the evasion of sanctions
transferring ownership of assets, investing in cryptocurrency, and even utilizing on a national level. Similarly, Russian oligarchs
Western legal systems to challenge designations. For instance, Alexei Mordashov,
have used Western legal systems to combat
one of the country's wealthiest individuals, quickly moved his shares in the German designation, such as Roman Abramovich's
travel group TUI to a Caribbean shell company controlled by his partner. Additionally, 2021 libel case against Catherine Belton's book
Russian citizens have increasingly shown an interest in stablecoins as a store of value, 'Putin's People.' Yevgeny Prigozhin, known
and means of exchange. Some oligarchs have used cryptocurrency to move assets as 'Putin's Chef,' has supposedly hired US and
and purchase goods in locations such as the UAE. Despite these efforts, analysts UK law firms to oppose his designation, while
suggest that the cryptocurrency market needs more liquidity to support the Alexander Abramov, a Russian steel mogul,
widespread evasion of sanctions. Furthermore, some individuals have taken the EU
has initiated legal action in Australia against
to court to contest their inclusion on the sanctions list, while others have hired US
the foreign affairs minister for his designation.
and UK law firms to challenge the designation.
13 14
Russia is in a strong position in Ukraine If discussions progress, Russia will probably

look for sanctions to be lifted as a reward
but is fragile overall geopolitically. for good conduct. This has already been
suggested by the November request from
The implementation of sanctions against Russia in 2023 will likely be determined by Russia to Western countries to remove the
developments on the battlefield in Ukraine. Russia has been unable to overthrow the Ukrainian designation of Russian state-owned
government led by President Volodymyr Zelenskyy nor occupy the country. Although they have agricultural lender Rosselkhozbank,
made territorial gains in the east and south, Ukrainian forces have had some success with so that it can help export Russian food
counter-offensives and forced the Russian army to retreat from the city of Kherson in November. to address global food supply chain
As fighting continues, Russia is slowly losing control of previously gained land.
difficulties. More of these 'goodwill'

exchanges will likely arise, particularly
They have resorted to drone attacks on energy infrastructure and civilians to weaken Ukrainian regarding energy supplies, and some
morale. With the possibility of Belarus joining the war and a full mobilization of the Russian army of them may well be accepted.
still under consideration, it is feasible that they could make a military breakthrough in 2023.
However, the use of nuclear weapons could cause a further escalation of the crisis and
What does it mean for you?
potentially trigger opposition from neutral countries, as well as having an environmental impact
in Russia itself. At the same time, evidence suggests President Putin has no intention of ending
Although firms should always be prepared
the conflict, and he may be waiting to see how winter affects Europe's commitment to sanctions
for further modifications to the Russian
and support for Ukraine.
sanctions list, they should also have

efficient and comprehensive screening
It appears that Russia is not likely to gain a decisive victory or concede defeat in the conflict with
tools. It is, therefore, crucial for them
Ukraine, and it is likely that a "steady state" will ensue. Ukraine will likely make small territorial
to partner with vendors that can provide
gains, as seen in Kharkiv and Kherson, and Russia will experience the occasional success. Rather
this service. Furthermore, firms should
than major battlefield changes, Ukraine will continue to conduct covert operations such as the
ensure their sanctions compliance
attack on the Crimean Bridge, while Russia will launch missile and drone strikes against Ukrainian
measures are comprehensive enough
infrastructure and civilians. Eventually, negotiations for ending the war may take place, but it is
to detect potential Russian sanctions
unlikely that either side will make significant concessions. With regards to Western sanctions,
exposure. Western agencies are paying
further restrictions on Russian natural gas supplies or financial institutions are expected to be
greater attention to the private sector's
limited unless there is a major escalation in Russian violence. However, more designations for
implementation of sanctions and
existing sanctions, shortened implementation timelines, and stronger measures to combat
attempting to curb evasion.
evasion may be enacted.
15 16
compliancevision.com Geopolitical Tensions & Economic Warfare Sanctions in 2023
The US sanctions Since 1979, Iran has been the target of numerous US
regime
sanctions in response to the overthrow of the former US
ally, the Shah, by Ayatollah Khomeini's Islamist extremist
revolution. After the release of US hostages taken by
the new regime in 1981, the US focused on Iranian state

terrorism and overseas interference by the Iranian
The United States, enforced primarily by the Department of Treasury's Office
intelligence services and IRGC, support for Islamist groups
of Financial Assets Control (OFAC), has the most widely recognized sanctions like Hezbollah and Hamas, human rights abuses, cyber
regime outside of the UNSC. This regime is based on legislation and Presidential criminality, and attempts to develop weapons of mass
Executive Orders (EOs), country-specific or thematic designations of entities destruction and ballistic missiles. The US has frozen Iranian
and individuals and is supplemented by the Bureau of Industry and Security assets, barred Iranian involvement in the US-dollar
(BIS) of the US Commerce Department's Entity List. The US sanctions are distinct -financial system, and prohibited them from selling their
in that they apply to those subjects to the legal authority of the sanctioning primary commodities, oil, gas, and other petrochemicals.
authority (primary sanctions) and non-US citizens and entities engaging with It also targets key regime figures with asset freezes
designated targets (secondary sanctions). In particular, the US has been

and transactional and travel bans.
an innovator in expanding its sanctions to human rights abuses, exemplified
by the Global Magnitsky Act in December 2016, named after Sergei Magnitsky, The UN Security Council, the EU, Canada, the UK,
who died from mistreatment in a Russian prison, in November 2009.
and others joined the US in condemning Iran's nuclear

ambitions and human rights violations. The EU imposed
40 years of US sanctions in Iran
sanctions on Iran's financial, energy, and transport sectors

and banned the import of Iranian oil and gas. In July 2015,
This year has seen a shift in focus to Iran, with the country surpassing specific US, EU, and UN sanctions related to Iran's nuclear
Afghanistan to become one of the top four geopolitical hotspots firms are program were partially lifted after the signing of the JCPOA
concerned with. This is due to the resurgence of old Western worries regarding between Iran and the five permanent UNSC nations plus
Iran's human rights record, domestic repression, funding of terrorism, and its Germany and the EU. Under the agreement, Iran was
ties to the Russian war effort. Moreover, there has been difficulty in reviving
granted access to the international financial system,
the Joint Comprehensive Plan of Action (JCPOA) - the agreement on the limits
global markets for commodities, and limits
to Iran's nuclear program - which has been partially moribund.

on uranium enrichment. However, the Trump
Despite this, the main focus of sanctions developments in 2022 has been administration withdrew from the agreement in May 2018
Russia's invasion of Ukraine. and reimposed US sanctions. The fate of the JCPOA
remains uncertain as of the start of 2022, despite the talks
to revive the deal encouraged by the Biden administration.
17 18
What to expect next?

At the start of 2022, there was optimism that US-Iranian relations would be improved,
and sanctions alleviated. However, the opposite occurred, with talks in Vienna leading
to progress and a draft agreement by the EU High Representative for Foreign Affairs and
Security Policy, Josep Borrell, in early August. Yet, the US and Iran were reluctant to agree,
citing the need for stronger guarantees on economic sanctions relief and the end
to an ongoing IAEA investigation. By mid-September, Borrell described the talks as being
at a standstill. Factors contributing to the stalemate included the US' mid-term congressional
and gubernatorial elections and long-term issues such as Iranian military interference
in the Middle East. This was compounded by the death of Mahsa Amini in Iranian custody,
followed by protests against the regime, and Iran's support for Russia's invasion of Ukraine,
providing military drones and advisers. All of this has made it challenging to advance
US-Iranian relations.
On September 16th, a Kurdish Iranian woman, Mahsa Amini, aged 22, died while in the custody
of the Gasht-e Ershad, the Iranian Morality Police, who had arrested her for reportedly breaking
the dress code. Though the police stated her death was due to an underlying medical
condition, many believed it was due to the harsh treatment she received, sparking outcries
and protests across the nation. The Iranian government responded to these demonstrations
with riot police, jailing protest leaders, and blocking some social media use. Additionally,
Iranian President Ebrahim Raisi backed Russia's invasion of Ukraine, disregarding global
criticism, and providing military drones and advisers to assist the weapons' deployment.
19 20
What’s next?
Sanctions response Overall, the prospects for Iranian relations with the US
and other Western countries in 2023 are not looking too

positive. Despite the potential for positive developments
In response to the lack of progress in nuclear talks and the general deterioration
of Iranian-Western relations, a range of sanctions on Iran were extended
in the Vienna talks, EU foreign affairs lead Josep Borrell's
and continued in 2022, particularly those imposed by the US. These included relative pessimism and the wide gap between the US and
sanctions for weapons proliferation (such as designating Iranian national Iran suggest that it is unlikely that the JCPOA will be
Mohammad Ali Hosseini and a network of companies for procuring ballistic revived in 2023. In addition, President Biden's hesitance to
missile propellants from China using false shipping documentation), oil sales give his potential political opponents a platform to criticize
(targeting individuals and front companies operating networks in East and him and the fear of a newly appointed hawkish Israeli
Southeast Asia to sell Iranian oil and petrochemicals, with proceeds supporting government under Binyamin Netanyahu using military
the IRGC’s Quds Force and Hezbollah), and cybercrime (sanctioning the Iranian force against Iranian reactors will likely cause the US to be
Ministry of Intelligence and Security and Minister of Intelligence Esmail Khatib
increasingly cautious in their dealings with Iran.
for mounting cyber and ransomware attacks, as well as targeting several

Iranian nationals and Iran-based companies linked to IRGC ransomware To make matters worse, the EU, Canada, and the UK are
attacks and users of Iran’s largest cryptocurrency exchange Nobitex.
likely to take a more hard-line stance against Iran, with the

UK taking more independent action in areas such as
In September 2022, the US, EU, Canada, and the UK imposed sanctions against Iranian support for terrorism due to comments made by
the Iranian Morality Police, its leadership, and other Iranian agencies like the Law MI5 Director General Ken McCallum in November 2022.
Enforcement Forces (LEFs) involved in internal repression.
In addition, they implemented joint action against Iranian support for Russia, What does this mean for you?
designating Iranian companies and individuals interested in the production,

production, and delivery of the Shahed drone series that Russia employed
Firms that could potentially face Iranian sanctions should
in Ukraine. Of the two Western activities, the one that seems to have had the anticipate no alteration. Companies must continue
most noticeable effect on Iran was the measures against domestic repression. to enforce rigorous due diligence and screening strategies,
Iran's Ministry of Foreign Affairs denounced the sanctions in October.
and those situated in areas utilized as bases for Iranian
It issued its own countersanctions against entities and individuals in the EU
secret acquisition and commodity trading - especially
and UK, including civil society groups, media outlets, politicians, and journalists, the Middle East, East and Southeast Asia - must make sure
which the Iranian government claimed were “inciting riots, violence,
to reduce risks from Iranian evasion operations using
and terrorist acts” in Iran.
proxy front companies.
21 22
Part 2: Global trends, regional impacts

The rise of China
Over the past decade, the US and its allies have come together to create
mechanisms to counterbalance China. These include the 'Five Eyes' group,
the Quadrilateral Security Dialogue, or 'Quad', established in 2004 by the US,

In our Geopolitics of Financial Crimes 2022 report, we identified China as the
Japan, Australia, and India, and the AUKUS partnership of Australia, UK,
primary source of new sanctions risk. However, the crisis in Ukraine

and the US, formed in 2021. Much of this collaboration has been centered
overshadowed these concerns in 2022, and China has adopted a cautiously

on coordinating military and intelligence activities, leaving economic
balanced approach to the invasion, showing support for Russia and peace.
statecraft instruments aside. As a result, the US has taken the lead in using
Beijing has been preoccupied with managing the Covid-19 pandemic and
sanctions as a tool for international influence against China. This is evidenced
further consolidating President Xi's power with his appointment to a third term
by the US's long-standing embargo, imposed in 1949 following the
at the Chinese Communist Party's 20th Congress in October. Despite this,
Communist victory in the Chinese Civil War, and an ongoing arms embargo
underlying tensions between China and Western countries remain,
since the Tiananmen Square protests in 1989. However, most of the current
particularly regarding the status of Taiwan. The Struggle for Global Leadership
China sanctions framework has been developed through the Trump and
The Western sanctions against China are a consequence of the country's
Biden administrations.
growing global political and economic power over the past forty years. Since
2000, China's GDP has grown from $1.2 trillion to $17.7 trillion, making it the
In November 2020, President Trump signed an Executive Order which
second largest economy in the world, and likely to become the biggest in the
prevented US citizens and entities from investing in companies designated
next decade. This rise is not necessarily a problem, as China has been an
by the DoD as Communist Chinese Military Companies (CCMCs). This was
active participant in trade with Western countries. Nevertheless, the US and its
followed by an updated Executive Order from President Biden in June 2021,
allies have become increasingly worried in the last decade with how this
expanding the scope of companies that could be deemed to be aiding
economic strength has enabled the spread of Chinese influence across Asia,
the Chinese military-industrial complex, Chinese overseas activities, and
Africa, and Europe via the Belt and Road trade initiative, the expansion of a
domestic repression. In May 2019, President Trump issued an Executive Order
tech-savvy Chinese military, and China's attempts to expand its control
banning the use of equipment from Chinese technology firms deemed
around the South and East China Sea islands. Additionally, Western
a national security risk. This was followed by the Secure and Trusted
governments have expressed concern over the Chinese government's stricter
Communications Act of 2019 and the Secure Equipment Act of 2021, which
domestic surveillance practices, the persecution of minorities such as the
further excluded Chinese telecommunications firms from the US. In June 2020,
Muslim Uyghurs in Xinjiang, and the diminishing of civil liberties in Hong Kong.
President Trump signed the Uyghur Human Rights Policy Act, authorizing
the president to designate Chinese individuals responsible for the persecution

of the Uyghurs, who were subsequently sanctioned by the Trump
administration. Finally, in December 2021, President Biden signed the Uyghur
Forced Labour Prevention Act, preventing the US from importing goods made
with forced labor in Xinjiang.
23 24
In 2019, President Trump signed the Hong Kong Human Rights and US and China relations in 2023
Democracy Act, followed by the Hong Kong Autonomy Act in 2020.
These laws provided legal grounds for the designation of Chinese and Hong Relations between Western countries and China in 2022 have remained
Kong individuals responsible for human rights violations and those who had largely contained despite the darkening background. The US and other
undermined Hong Kong’s autonomy. Consequently, a number of senior Hong countries have boycotted the Winter Olympics in February and a UN report
Kong officials, including the then Chief Executive Carrie Lam, were sanctioned. in August that suggested the mistreatment of Uyghurs amounted to "crimes
The Act also mandated the designation of Foreign Financial Institutions (FFIs) against humanity" has further increased tensions. However, the level
assisting targeted people.
of argument between China and the democratic coalition over human rights
issues has only 'simmered' rather than boiled. President Biden's statement
Prior to 2022, the US had been the main driving force behind a wide-reaching in March that there would be "consequences" for Chinese "material support"
set of sanctions against China in response to its activities.

of the invasion has seemingly been heeded by President Xi. China has since
By the spring of 2021, signs were showing that some of its allies were been careful to not condemn Russia, instead expressing the importance
beginning to follow suit, particularly in regards to the human rights abuses

of both Russia and Ukraine's state sovereignty and the need for peace. Blame
in Xinjiang. The European Union, the United Kingdom, and Canada all has been laid primarily on the West, citing NATO expansion as the cause
implemented similar, joint measures against key Chinese players involved

of legitimate security fears in Russia.
in the persecution of the Uyghur population. In return, China retaliated with

designations against US, EU, UK, Canadian, and Taiwanese officials
In July, US intelligence reports indicated that the Chinese government had
and politicians in 2020 and 2021.
not taken any action to provide economic, financial, or military suppor
It also imposed heavy tariffs on Australian imports and removed

for Russia or to help evade Western sanctions. However, tensions between
its ambassador from Lithuania in retaliation for the country's announcement the US and China have been most prominent over the status of Taiwan.
about Taiwan opening a trade office in Vilnius in November 2021. Furthermore, The island, home to the Kuomintang, the Chinese Communists' civil war
it implemented a sanctions framework meant to target foreign businesses, opponents, has not been recognized as an independent state by the US
beginning with the release of an 'Unreliable Entities List' (UEL) in 2020

or other Western states since 1979. Despite this, the US and other Western
and followed by a Blocking Statute and an Anti-Foreign Sanctions Law (AFSL)
states have been providing support for Taiwan in the face of Chinese
in 2021. The measures had only been used in limited capacities up until
demands for it to become part of the 'One China' policy. This issue has been
the end of 2021, with the exception of a warning to add Western defense firms a source of contention between the US and China since the 1950s,
such as Lockheed Martin and Raytheon Technologies to the UEL for providing leading to a number of crises.
defense equipment to Taiwan in October 2020.
25 26
In May of 2022, President Biden's statement in Tokyo that the US would use China issued its own sanctions in response to US activity, mainly targeting
military force to protect Taiwan angered the Chinese Foreign Ministry, leading Taiwan. Following a trip to Taiwan, the Chinese Ministry of Foreign Affairs
to the cancellation of security dialogues with the US and military exercises announced personal sanctions on Nancy Pelosi, her immediate family
around Taiwan. Chinese President Xi Jinping declared China's right to use
members, and a mid-ranking Lithuanian minister who visited Taiwan
"all necessary measures" concerning Taiwan at the October Party Congress. the same month. China also continued to target US defense firms that had
However, by the end of the year, tensions had eased enough for Biden and Xi provided equipment for the government of Taiwan, making new threats
to meet at the G20 Summit in Bali, where they had frank discussions
to sanction Raytheon and Lockheed Martin in February and saying that
but appeared to have calmed tempers. In response to the geopolitical personal sanctions would be applied to the CEOs of Raytheon and Boeing
environment, Western sanctions activity against China was comparatively Defense following a new arms deal with Taiwan later in the year.
subdued. The US Department of State imposed visa restrictions on certain However, the Chinese government did not apply sweeping designations
Chinese officials accused of domestic oppression in March, and the Uyghur of the US or other firms in response to technology controls or other previous
Forced Labor Prevention Act, passed in December 2021, took effect in June.
measures in regard to Xinjiang or China.
The EU, UK, Canada, and others also failed to take additional measures
on human rights issues in China, despite pressure from civil society groups What does it mean for you?
after the UN report in August.
Companies doing business in East and Southeast Asia should keep a close
In 2022, the US took further action against Chinese firms in the context
watch on the US-China relationship, paying attention to any changes in their
of sanctions evasion activity linked to Iran and North Korea, with the BIS rhetoric. However, only a significant dispute over Taiwan will likely cause
adding 36 firms to its Entity List for aiding Russian sanctions evasion,
a significant alteration in the existing sanctions. The US and its allies are likely
25 of which had China-based operations, and five of which were Chinese to continue imposing sanctions related to human rights violations, and the US
incorporated businesses. The most significant US sanctions activity against will further strengthen export regulations for companies providing technology
China that year was in the area of technology, with 33 China-based to Chinese organizations. Additionally, the US is likely to enforce severe
companies being added to the BIS Unverified List (UVL) in February and seven punishments for Chinese or Hong Kong organizations possibly involved
Chinese firms in space and aerospace technology being added to the main in skirting sanctions in Russia. Thus, it is essential to carry out screening
Entity List in August. October saw new regulations prohibiting the US

and surveillance to identify any concealed ties to such activities.
and US-based companies from exporting advanced chips and software
related to machine learning to China and banning covered businesses from
manufacturing advanced chips for Chinese firms, impacting the operations
of some of the world’s largest technology companies.
27 28
Instability of North Korea

North Korea, officially the Democratic People's Republic of Korea (DPRK), is one of the most
intractable international issues, and has been subject to comprehensive sanctions since
the outbreak of the Korean War in 1950. Sanctions have targeted North Korea's conventional
weapons proliferation, terrorism, overseas political interference, illegal activities such as drugs
trafficking, counterfeiting, smuggling, cybercrime and money laundering, human rights
abuses, and WMD development. The US has been the primary designator of North Korea,
but the wider international community has also followed suit. In 2022, two reports from the UN
Panel of Experts (PoE) on North Korean sanctions indicated that the North Korean regime had
continued to source sanctioned items for its WMD programs, buy and sell goods beyond UN
limits, and generate hard currency through illegal activities, with the help of complex webs
of front companies and logistics firms and vessels based across numerous jurisdictions.
To reduce the risks from North Korean evasion operations, the international community must
take steps to make sure that proxy front companies are not being used.
29 30
Rise of cyber-warfare Throughout the year, North Korea has attempted
In March and September of 2022, the UN Panel of Experts (PoE) produced two to show off the results of its proliferation activities.
reports indicating that North Korea had continued its clandestine proliferation In March, they announced they had launched
activities, despite the sanctions imposed and the country’s own border closure, the Hwasong-17, the largest Intercontinental Ballistic
initiated in January 2020 for Covid-19. As with previous reports, the PoE Missile (ICBM) that could allegedly hit any part
determined that North Korea had sourced items necessary for its WMD of the continental US. Subsequent analysis suggested
programs, sold and bought goods like oil and coal beyond UN regulations,
it might have been a smaller missile, the Hwasong-15.
and generated currency through illicit activities, including supplying illegal labor. Several other ICBM tests were reported, including one
These activities are managed by North Korea’s diplomatic and official in November close to the Japanese island of Hokkaido
presences, as well as by networks of front companies and logistics firms
that fell in the Sea of Japan. North Korea also tested
and vessels based in various jurisdictions.
a variety of other missiles, from short, medium,
to intermediate, which could be used to target Japan

Such entities are used to mask links to the North Korean government
and South Korea. According to an analysis from Al
and the clandestine Offices 38 and 39, believed to be the overseers of overseas Jazeera in November, North Korea had tested more
activities. To avoid potential evasion operations by Iranian proxies, countries
than 60 missiles in 2021, the largest number ever
in the Middle East, East and Southeast Asia must minimize the risks
in a year. This led some, including the South Korean
from front companies
government, to speculate that North Korea was

preparing for its seventh nuclear test, the first since
According to reports, North Korea has become increasingly reliant
2017. Additionally, North Korea has purportedly joined
on state-sponsored cybercrime. The country is believed to employ around 6,000 Iran in supplying material aid to Russia for its invasion
hackers in different operational units, such as the 'Lazarus Group',
of Ukraine.
to carry out phishing, malware, and social engineering attacks. Chainalysis data
revealed that North Korea had stolen around $400 million in cryptocurrency
In July, the Russian Ambassador to Pyongyang
in 2021, a significant increase compared to 2020. Additionally, the US and PoE proposed that North Korean labor could be utilized
(Point of Execution) both attributed two major hacks in 2022 to North Korea.
to rebuild Donbas and Luhansk, and by autumn it was
In March, North Korea's hackers reportedly stole around $650 million in Ethereum reported that North Korean factories were producing
and USD Coin from Ronin Network, a platform for the mobile game Axie Infinity, military uniforms for Russia and supplying the Russian
and in June, the equivalent of around $100 million was taken from Harmony army with Soviet-era munitions.
Horizon, a cross-chain bridge used to migrate assets between multiple
blockchains, using similar methods as the Ronin attack
31 32
US sanctions against North-Korea

New sanctions were primarily implemented at a national level, primarily as a platform used by criminals to launder funds, including $455 million taken
from the US, focusing on missile and fuel procurement. OFAC designated
by the Lazarus Group. Other North Korean-related cyber designations were
a number of entities, individuals, and financial institutions for their made throughout the year, including two Chinese nationals linked to the
involvement in procuring items for WMD and ballistic missile production,
Lazarus Group in March and several Ethereum addresses linked to laundering
while the BIS placed export controls on a Chinese firm. Additionally, OFAC funds from the Ronin Network hack in April. The US was not alone in taking
sanctioned three individuals and four companies for supporting petroleum action, and its allies also implemented additional measures due to North
exports to North Korea through ship-to-ship transfers. In January, April, and Korean activities and the stalemate in the UNSC. April saw the EU impose
May, the Office of Foreign Assets Control (OFAC) designated several entities sanctions on eight North Korean nationals, including senior officials and
and individuals to assist in procuring goods for the production of Weapons
individuals involved in proliferation activities in sub-Saharan Africa, as well as
of Mass Destruction (WMDs) and ballistic missiles. This included the North entities like three North Korean state trading corporations and an Eritrean
Korean Ministry of Rocket Industry (MoRI) alongside multiple trading technology firm. The UK added North Korean nationals, a North Korean trading
companies and North Korean nationals based in Russia and China. OFAC also corporation, and a Chinese logistics firm to their list throughout the year,
sanctioned two Russian financial institutions, Bank Sputnik and Far Eastern and Australia added three entities to its autonomous regime - one North
Bank, and a Russian national for aiding North Korean procurement
Korean and two Russian - following the missile test in March. Additionally,
and proliferation financing.
Japan added five North Korean state entities linked to weapons development
to its own North Korean sanctions list after the ICBM test in October. Given
Additionally, in February, the Bureau of Industry and Security (BIS) imposed North Korea's recent focus on cyber-crime and cryptocurrency heists, they will
export controls on a Chinese firm for providing North Korea with aluminum likely continue on this path in 2023. However, a prolonged drop in the value
powder which could be used for ballistic missile propellants. For October, of cryptocurrencies might lead them to switch tactics and return to targeting
OFAC designated a group of three individuals - from Singapore, Malaysia,
fiat currencies, similar to their attempt to steal $1 billion from the Federal
and Taiwan - along with four companies from Singapore, Malaysia,
Reserve Bank of New York's accounts with Bangladesh Bank in February 2016.
and the Marshall Islands for enabling petroleum exports to North Korea
through ship-to-ship transfers. Singaporean Kwek Kee-Seng was also wanted The prospects of any improvement in the stalemate between Western
in an FBI-led inquiry into sanctions evasion and money laundering.
countries and North Korea appear slim. It is likely that the situation will only
worsen, with North Korea potentially carrying out a nuclear test, launching
In May of 2020, OFAC (Office of Foreign Assets Control) designated Blender,
more missiles close to South Korea and Japan, or providing more support
a cryptocurrency mixing service, after the Lazarus Group used it to launder for Russia in Ukraine. China and Russia's block at the UNSC will likely prevent
$20.5 million of the funds stolen from the Ronin Network hack. This was the first any new resolution from being implemented. Therefore, the US, EU, UK,
designation of its kind. August of that same year saw Tornado Cash being Australia, and Japan will probably take unilateral action, with the US focusing
designated by OFAC after it was identified
on North Korean cybercrime and cryptocurrency theft, and all countries likely
augmenting their lists due to a potential nuclear test by North Korea.
33 34
What does it mean for you?

US and entities exposed to US jurisdiction should already be cognizant of the broad scope
of US sanctions against North Korea, but it is important to remain vigilant for any changes
to the list of designations in 2023, especially concerning cryptocurrency-related entities.
The US's choice to target two cryptocurrency mixers alleged to have enabled North Korean
money laundering shows that all CASPs must closely examine their due diligence, scanning,
and monitoring processes to guarantee they do not breach OFAC regulations.
Not knowing the rules is not an acceptable excuse.
35 36
Europe remains a solid
Western ally for the US.
Western countries have acted in order to support
In 2022, relations between Western countries and Belarusian President

the stability of Bosnia and Herzegovina, despite
Alexander Lukashenko were strained due to his repressive domestic

the Russian influence in the region. Sanctions have
measures and close relationship with Russia. As a result, the US, EU,
been imposed by the US, EU, and UK on those who
Canada and the UK imposed sanctions against Lukashenko, members
have sought to undermine the Dayton Peace Accord

of his regime and state institutions, and state-owned businesses
of 1995, which ended the country’s civil war.
in response to rigged presidential elections in 2006 and 2020, the violent

This includes Milorad Dodik, the Bosnian Serb leader,
suppression of public protests, and the kidnapping of domestic dissident
Marinko Cavara, the President of the Bosniak-Croat
Raman Pratasevich and his girlfriend from an airplane in May 2021.
federation, and various corrupt state officials
In addition, in February 2022, Lukashenko allowed Russian troops to be

and business people. The EU has decided to extend
used as a base for operations, leading to further sanctions against
their sanctions regime until March 2024, and the UK
Belarus, including personal sanctions on members of the regime,
has imposed sanctions on Dodik and Zeljka
transaction prohibitions with the Central Bank of Belarus, the removal
Cvijanovic, currently the Serbian representative
of several major Belarusian banks from SWIFT, limitations on financial

in Bosnia’s federal presidency. With Bosnia facing
transactions, and restrictions on trade in key sectors such as defense
a potential collapse into disorder in 2022, further

and technology. Separately, the US also sought to target Russia’s
designations in 2023 may be necessary due to the
European allies more widely in October 2022, when it designated nine
extreme nationalist politicians that have retained
corrupt politicians, officials and oligarchs, and a number of linked

their primary positions.
businesses in Moldova. These individuals were alleged to have worked
to undermine Moldovan elections in 2021 on behalf of Russia.
In 2023, more measures against Belarus are expected to follow a similar
pattern as those imposed on Russia, though they could widen and grow
deeper if Belarus were to commit its own troops to Ukraine.
37 38
Asia: next political hotspot Africa: next hotspot?
Western attention has largely been on the events in Europe and

In 2022, Myanmar continued to be a subject of great concern, due to
Asia in 2022 while new sanctions measures in Africa have been

the military coup that took place in February 2021. Western governments
kept to a minimum. Following the military takeover of Sudan
called for the release of overthrown leader Aung San Suu Kyi and a stop
in October 2021, many international institutions and Western

to the oppressive behavior against protestors. Although the UNSC's
countries suspended aid to the country. In March 2022, the US took
sanctions were blocked by China, the US, EU, Canada, and UK took
action by imposing sanctions on Sudan’s Central Reserve Police
individual action and implemented sanctions on high-ranking military
for their mistreatment of civilians protesting the coup. The US also
officials, government enterprises, and businesses in Myanmar's influential
designated three politicians in Liberia in August of the same year
sectors such as timber trading and mining.
for their involvement in corruption.
By 2022, the US and other international players had implemented a variety

By 2022, African states had begun employing sanctions as a form
of measures, including sanctions and designations, in response
of influence, particularly with regards to democracy,
to the military regime in Myanmar and its private sector supporters.
with the Economic Community of West African States (ECOWAS)

These measures were further intensified in February in recognition
leading the charge. At the end of 2021, ECOWAS warned that they
of the anniversary of the coup, with the EU targeting the state-owned
would impose sanctions on the military regime in Mali if they
energy firm, Myanma Oil and Gas Enterprise (MOGE). As the military
failed to hold democratic elections in early 2022; this threat was
regime continued to oppress Aung San Suu Kyi, who was placed on trial
followed through in January, with a full financial and trade

in 11 separate corruption cases, the US responded with specific action
embargo imposed. These sanctions immediately succeeded;
against figures in law enforcement and the judiciary in January.
ECOWAS lifted them in July following the Malian military’s

The US also noted Myanmar's ties to Russia and designated three
agreement to transition to democracy within two years, backed
Myanmar businessmen and their business in October for buying Russian
by a new election law. This September, ECOWAS once again

-produced arms for the regime. By the end of the year, Myanmar's
employed economic statecraft, announcing more limited
isolation from the international community had increased, with the
sanctions against the military regime in Guinea for their lack
Financial Action Task Force (FATF) placing them on the list of 'High-Risk
of progress towards democracy. This was followed by a military
Jurisdictions.' With no sign of the Myanmar regime changing course
coup in Burkina Faso in the same month, and ECOWAS

in the near future, it is likely that the US and others will continue to tighten
encouraged the military regime in Ouagadougou to plan
sanctions in 2023, particularly following further guilty verdicts in Aung San

for a return to democracy. Should progress remain uncertain,
Suu Kyi's trials and any evidence of support for the Russian invasion
there is the potential for ECOWAS to take further measures against

of Ukraine.
the country in 2023.
39 40
“Americas” and the US neighbor

Since 1979, President Daniel Ortega has been a major political force in Nicaragua. He was the national leader between 1979
and 1990 and then again from 2007 onwards, during which time he and his allies in the leftist Sandinista movement have
held a great deal of power. Over the last five years, this control has been met with a steady accumulation of sanctions from
the US, EU, UK, and Canada. In November 2021, the situation escalated further when Ortega was declared the winner
of a widely-condemned, fixed presidential election, granting him a fourth consecutive term in office. President Biden then
signed Reinforcing Nicaragua’s Adherence to Conditions for Electoral Reform Act, which enabled additional sanctions
against the regime.
In January and June of 2022, the US imposed new sanctions on Nicaraguan regime officials and a mining company,
followed by President Biden signing an Executive Order in October that targeted the gold sector of the Nicaraguan economy
and designated the Nicaraguan national mining authority. These measures came in response to President Ortega’s refusal
to reform, which was made clear by the fraudulent municipal elections in November of 2022. However, the situation
in Venezuela may be looking brighter for the US, with reports of President Maduro’s willingness to talk to domestic
opponents in return for some sanctions relief. Should this occur, the US may relax some sanctions against Venezuela
in 2023, allowing Chevron, a major US oil firm, to engage with the Venezuelan state-owned oil company, PDVSA, though not
to drill or export any petroleum of Venezuelan origin. Despite this potential development, President Biden will face criticism
from the Republican Party should he decide to ease any restrictions on Venezuela.
In November, OFAC designated two Russian and Belarusian nationals and their businesses for their use of bribery to gain
influence in Guatemala's mining sector. This further development in Latin America demonstrated that the US intends
to trace and tackle Russian interference around the world, in addition to its sanctions in response to the invasion of Ukraine.
41 42
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Geopolitical Tensions &amp; Economic Warfare Sanctions in 2023

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Geopolitical

Part 1: Global political instability Part 2: Global trends, regional impacts

05 Russia 23 China & North Korea

17 The US Sanctions Regime 37 Europe

21 Sanctions response 39 Asia, Africa & “Americas”

of Ukraine began in February 2022. It accelerated pre-existing trends in

Sanctions on sanctions could be used again in similar crises.

As we entered 2023, geopolitical tensions between increasingly polarized camps

networks, and individuals. When imposing sanctions,

the US and China, which, while self-governing, is seen as a part of China by

Russia’s military aggression in Ukraine

in Ukraine with sanctions targeting official institutions, businesses, groups, networks,

or via carriers under its authority.

Western allies' common response

respective allies have been most notably with the illegal

Putin, politicians, military officers,

of attempting to encircle Russia

the democratic world has increased again as Putin voiced

reprimanded Putin for his regime's his displeasure with Ukraine's

countries joined them, including the EU,

Norway, Switzerland, Iceland, the UK,

Canada, Australia, New Zealand, Japan,

of contention, however, has been officially recognized

- imposed autonomous sanctions for

Ukraine. Putin considers

the first time. The most significant

sanctions were imposed in the first few

months after the invasion, but new

packages have been introduced across

The countries involved have all implemented different measures,

but their responses have been highly coordinated and similar.

Financial sanctions have also been imposed, such as asset freezes

government from using foreign currency reserves or selling assets

and the EU (joined by Australia) established the Russian Elites, Proxies,

The REPO Task Force has played an essential role in fostering

to generate funds to back the Russian war effort by means

based on existing fraud, money laundering, and sanctions legislation

sanctions evasion to the RICO Act.

Finally, the European Commission and the Canadian government have

The European Commission's proposed Directive of Asset Recovery and

the seizure of assets from individuals deemed a risk to international

Russian response to the West

sanctions still need to achieve their goal of persuading President Putin to

introductions of sanctions that have allowed Russian individuals and

sought out crypto to circumvent Western

from crypto analytic firms such as Chainalysis

Russia is in a strong position in Ukraine If discussions progress, Russia will probably

difficulties. More of these 'goodwill'

sanctions list, they should also have

the new regime in 1981, the US focused on Iranian state

designated targets (secondary sanctions). In particular, the US has been

an innovator in expanding its sanctions to human rights abuses, exemplified

who died from mistreatment in a Russian prison, in November 2009.

and others joined the US in condemning Iran's nuclear

sanctions on Iran's financial, energy, and transport sectors

to Iran's nuclear program - which has been partially moribund.

What to expect next?

to an ongoing IAEA investigation. By mid-September, Borrell described the talks as being

and other Western countries in 2023 are not looking too

Geopolitical Tensions & Economic Warfare Sanctions in 2023

Geopolitical Tensions & Economic Warfare Sanctions in 2023

Geopolitical Tensions & Economic Warfare Sanctions in 2023