The U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License 8G (“GL 8G”), which authorizes five (5) U.S. oil and gas companies to engage in transactions “ordinarily incident and necessary to the limited maintenance of essential operations, contracts or other agreements”, as well as transactions necessary to the wind down of operations in Venezuela involving Petroleos de Venezuela, S.A. (“PdVSA”) or any entity which PdVSA owns a 50% or greater interest and that were in effect prior to July 26, 2019. Effective November 17, 2020, GL 8G replaces and supersedes GL 8F which was set to expire on December 1, 2020, effectively extending its deadline through 12:01 eastern daylight time on June 3, 2021. GL 8G applies specifically to the following entities and their subsidiaries: Chevron Corporation, Halliburton, Schlumberger Ltd., Baker Hughes (a GE company), and Weatherford International, PLC.
Continue Reading OFAC Issues Venezuela General License 8G Extending Authorization of Certain Transactions for U.S. Oil & Gas Companies
OFAC
U.S. Scheduled Bans on TikTok and WeChat Apps Delayed
China-based smartphone apps, TikTok and WeChat, have each received a reprieve from the respective bans, which were originally ordered by President Trump on August 6, 2020 against both parties and…
Continue Reading U.S. Scheduled Bans on TikTok and WeChat Apps Delayed
U.S. Increases Pressure on Russian Gas Pipelines with Imposition of New CAATSA Secondary Sanctions; Issues New General Licenses for Companies Doing Business with GAZ Group
The U.S. Department of State recently published updated guidance pertaining to Section 232 of the Countering America’s Adversaries Through Sanctions Act (“CAATSA”). The revised guidelines subject energy export pipelines originating…
Continue Reading U.S. Increases Pressure on Russian Gas Pipelines with Imposition of New CAATSA Secondary Sanctions; Issues New General Licenses for Companies Doing Business with GAZ Group
OFAC Issues General License 5D for Venezuela Sanctions
The U.S. Department of Treasury’s Office of Foreign Assets Controls (“OFAC”) issued General License 5D pertaining to the Venezuela sanctions. Effective July 15, 2020, General License 5D replaces and supersedes…
Continue Reading OFAC Issues General License 5D for Venezuela Sanctions
State and Treasury Departments Designate 39 Entities under “Caesar Act” Syria Sanctions
New U.S. sanctions on Syria took effect on June 17, 2020 as a result of the “Caesar Syria Civilian Protection Act of 2019” (“Caesar Act”) that was signed…
Continue Reading State and Treasury Departments Designate 39 Entities under “Caesar Act” Syria Sanctions
OFAC Removes General License 13E and Issues General Licenses 3H and 9G
The U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) recently announced the removal of General License 13E (“GL 13E”), authorizing certain activities involving Nynas AB, a Swedish manufacturer…
Continue Reading OFAC Removes General License 13E and Issues General Licenses 3H and 9G
OFAC Fact Sheet on Humanitarian Assistance to Countries with Sanctions
The United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) released a fact sheet that outlines exemptions, exceptions, and authorizations for humanitarian assistance and trade under the…
Continue Reading OFAC Fact Sheet on Humanitarian Assistance to Countries with Sanctions
OFAC Extends General License for Companies Doing Business with PDVSA Affiliate Nynas AB
The U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) recently issued General License 13E (“GL 13E”), authorizing certain activities involving Nynas AB, a Swedish manufacturer of specialty oils…
Continue Reading OFAC Extends General License for Companies Doing Business with PDVSA Affiliate Nynas AB
OFAC Issues Two New General Licenses for Companies Doing Business with GAZ Group
The U.S. Treasury’s Office of Foreign Assets Control (“OFAC”) has recently issued two new General Licenses to extend pre-existing authorizations for transactions with GAZ Group that would otherwise be prohibited…
Continue Reading OFAC Issues Two New General Licenses for Companies Doing Business with GAZ Group
President Trump Imposes Sanctions Against Turkey for its Syria Offensive
On October 14, 2019, President Trump announced via Twitter his intention to authorize sanctions against Turkey and “any persons contributing to Turkey’s destabilizing actions in northeast Syria.” The announcement followed Turkey’s recent military operation against predominately Kurdish forces in northern Syria, which began following the withdrawal of U.S. troops from the region. Later in the day, President Trump issued an Executive Order (the “Syria-Turkey EO”) to formally implement those sanctions. Under the Syria-Turkey EO:
- The U.S. Secretary of the Treasury is now authorized to impose blocking sanctions on any person that it determines to be: (i) responsible for or complicit in actions that threaten Syrian stability or abuse human rights, (ii) an official or agency of the Government of Turkey, or (iii) operating in sectors of the Turkish economy that the Secretary of Treasury might later decide to target with sanctions. The Syria-Turkey EO also authorizes the Treasury Secretary to impose blocking sanctions on any person (including non-U.S. persons) who provides material assistance, goods or services to or in support of any person sanctioned under the Syria-Turkey EO.
- The U.S. Secretary of the Treasury is authorized to restrict or prohibit foreign financial institutions from opening or maintaining correspondent or payable through accounts in the U.S. if the Treasury Department determines that those foreign financial institutions have knowingly conducted or facilitated any significant financial transaction for or on behalf of any person who becomes subject to the above-described blocking sanctions.
- The U.S. Secretary of State is now authorized to impose menu-based sanctions on any person the Secretary determines to have interfered with peacekeeping and restorative efforts in northern Syria. These authorized menu-based sanctions include (but are not limited to): blocking sanctions, denial of U.S. entry visas and financing-based sanctions.
Continue Reading President Trump Imposes Sanctions Against Turkey for its Syria Offensive