Venezuela recently initiated a World Trade Organization (“WTO”) complaint against U.S. sanctions, claiming that the United States has “imposed certain coercive trade-restrictive measures on the Bolivarian Republic of Venezuela in the context of attempts to isolate Venezuela economically.” The same day, the U.S. imposed additional sanctions on Venezuelan nationals and entities allegedly engaging in corrupt currency exchange transactions (see our previous post here).
The WTO will now begin consultations, during which the parties will have an opportunity to resolve their dispute without entering into litigation. If the parties cannot reach an agreement within 60 days, Venezuela may request adjudication by a dispute settlement panel. It remains to be seen whether the WTO dispute settlement system will be of any assistance to Venezuela in light of predicted paralysis in December 2019 when two of the three current WTO judicial appointments are set to expire. To date, the United States has refused to entertain any appellate body appointments due to concerns that the current members have strayed from their original mandate.
Husch Blackwell’s Export Controls and Economic Sanctions team continues to monitor all matters related to sanctions as they develop and will provide updates and analysis as new information becomes available. Should you have any questions, please contact Cortney Morgan, Linda Tiller, or Grant Leach.
Today, January 8, 2019, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) 
On December 19, 2018, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) and the U.S. State Department took multiple sanctions actions related to Russia:
On December 7, 2018, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) further 
On November 9, 2018, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) extended the expiration date for certain Ukraine-related general licenses related to EN+ Group plc (EN+), United Company RUSAL PLC (RUSAL), and GAZ Group (GAZ). The expiration date of General Licenses 13G (Authorizing Certain Transactions Necessary to Divest or Transfer Debt, Equity, or Other Holdings in Certain Blocked Persons), 14C (Authorizing Certain Activities Necessary to Maintenance or Wind Down of Operations or Existing Contracts with United Company RUSAL PLC), 15B (Authorizing Certain Activities Necessary to Maintenance or Wind Down of Operations or Existing Contracts with GAZ Group), and 16C (Authorizing Certain Activities Necessary to Maintenance or Wind Down of Operations or Existing Contracts with EN+ Group PLC or JSC EuroSibEnergo) was extended from December 12, 2018 to January 7, 2019. U.S. persons participating in transactions or activities authorized by these general licenses should provide a detailed report to OFAC within 10 business days of January 7, 2019 (by January 21, 2019).
