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On November 12, 2021, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) sanctioned four entities and two individuals pursuant to Executive Order 14046, “Imposing Sanctions on Certain Persons With Respect to the Humanitarian and Human Rights Crisis in Ethiopia” (“EO 14046“).  These designations are in response to the growing humanitarian and human rights crisis and expanding military conflict in Ethiopia.  Our previous blog post on the issuance of EO 14046 can be found here.  This is the first round of sanctions imposed under EO 14046.  OFAC issued this press release announcing sanctions on these parties. 

US Persons are prohibited from dealing with the newly designated parties.  OFAC issued General License No. 4, “Authorizing the Wind Down of Transactions Involving Hidri Trust or Red Sea Trading Corporation” (“GL 4”).  GL 4 authorizes the winding down of transactions with Hidri Trust and the Red Sea Trading Corporation through 12:01 a.m. EST on December 14, 2021.  Both entities are among those sanctioned under this round of designations.  Other designations include Eritrea’s only political party and the country’s military. 

OFAC also issued FAQs 935 and 936.  FAQ 935 confirms that sanctions against Hidri Trust and the Red Sea Trading Corporation do not restrict the ability of interested parties to engage in humanitarian-related transactions or activity in Eritrea or Ethiopia.  FAQ 936 confirms that OFAC’s “50% Rule” does not apply for purposes of sanctions imposed under EO 14046.  Rather, the sanctions apply only to parties that are themselves sanctioned under EO 14046 and listed on OFAC’s Specially Designated Nationals and Blocked Persons List (“SDN List”)

Secretary of State Antonin Blinken issued a statement supporting these sanctions, saying they “build upon the United States’ previous actions to press the parties to move toward a cessation of hostilities and a peaceful resolution to the conflict.”  The statement also indicates further sanctions could be imposed should the parties fail to make progress in reducing conflict in the region and calls for Eritrean forces to immediately withdraw from Ethiopia.  The Government of Ethiopia and the military group Tigray People’s Liberation Front are explicitly referenced as sanctions targets.

The authors acknowledge the assistance of Ryan Orange with this blog post.


Sylwia Lis is a partner and member of the International Trade, Compliance and Customs Steering Committee in Baker McKenzie. She has extensive experience advising companies on US laws relating to exports and reexports of commercial goods and technology, defense trade controls and trade sanctions — including licensing, regulatory interpretations, compliance programs and enforcement matters. She also has advised clients on national security reviews of foreign investment administered by the Committee on Foreign Investment in the United States (CFIUS), including CFIUS-related due diligence, risk assessment, and representation before the CFIUS agencies.


Alexandre Lamy joined Baker McKenzie in 2009 and currently works in the Firm's International Trade Practice Group. He assists clients with sanctions and export controls (Export Administration Regulations (EAR); International Traffic in Arms Regulations (ITAR)) and he advises clients on corporate compliance matters. Since August 2011, Alex has served on the steering group for the ABA Section of International Law’s Export Controls & Economic Sanctions Committee and is currently a Vice Chair of the Committee. He has organized several events regarding recent developments in US trade sanctions and export controls for the Committee.

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