The release Monday of OFAC of the Non-SDN Communist Chinese Military Companies List (NS-CCMC) is an apt example of how, in some cases, sanctions programs have to adapt to fill in the gaps left by legislation or Executive Order. Remember the Venezuela General License that exempted transactions in all the Venezuelan government securities issues - except one? Well, this is another case...

And Mr. Watchlist hopes that this is just a good first effort... that Sanctions Clause brings more usable sanctions lists in the coming year, so that firms that don’t have core competencies in company research don’t have to identify as many parties sanctioned because they fall under a descriptive title in an Executive Order, a piece of legislation, or a guidance document.

Mr. Watchlist can dream, can’t he?

Happy New Year, everyone - and good riddance to 2020!