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 owned in part by PDVSA, Venezuela’s state-owned oil company, which would normally be prohibited by Executive Order 13850 (“E.O. 13850”).  The notice issued by OFAC

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 under OFAC’s Ukraine- and Russia-related sanctions. General License 15H (“GL 15H”) authorizes certain activities necessary to maintenance or wind down of operations or existing contracts

In a January 10th Executive Order, President Trump expanded sanctions on Iran after a ballistic missile attack on two American military bases in Iraq.  Executive Order 13902 expands secondary sanctions on Iran to include “significant” or “material” support transactions between non-U.S. persons and Iran’s construction, mining, manufacturing, and textiles sectors as potentially sanctionable

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

On October 7, 2019, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced that it would add twenty eight (28) Chinese entities consisting of companies, government offices, and security bureaus to the Entity List for engaging in or enabling activities contrary to U.S. foreign policy interests.  Similar to the actions taken against

On Wednesday, May 15, 2019, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced in a press release that it would add Huawei Technologies Co. Ltd. (“Huawei”) and additional Huawei affiliates to BIS’s Entity List.  BIS’s initial press release stated that this designation would become effective upon its publication in the Federal Register (which is scheduled for May 21, 2019).  However, a copy of the designation action posted in the Federal Register Public Inspection List on Thursday, May 16, 2019 stated that the designation would take effect on its May 16 Public Inspection List display date.  BIS explained that it is making this designation because it determined that “[T]here is reasonable cause to believe that Huawei has been involved in activities contrary to the national security or foreign policy interests of the United States.”  Among other reasons, BIS specifically cited Huawei’s Superseding Indictment in the US District Court for the Eastern District of New York for violating US sanctions against Iran.


Continue Reading

On April 21, 2019, the White House announced that President Trump has decided not to reissue the Iranian oil sanctions waivers, called “Significant Reduction Exceptions” (SREs) when they expire in early May. The White House statement explained that “[t]his decision is intended to bring Iran’s oil exports to zero, denying the regime its principal source of revenue.”
Continue Reading

On Sunday, January 27, 2019, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) announced the lifting of sanctions imposed on En+ Group plc (“En+”), UC Rusal plc (“Rusal”) and JSC EuroSibEnergo (“ESE”).  As previously reported here, this announcement follows the Administration’s notification submitted to Congress on December 19, 2018.
Continue Reading

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

Today, January 8, 2019, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) added approximately 30 individuals and entities to its Specially Designated Nationals and Blocked Persons List (the “SDN List”) due to their engagement in corrupt currency exchange transactions which enriched themselves by at least $2.4 billion at the expense of Venezuela’s citizens.  These sanctioned persons include two former Venezuelan National Treasurers – Claudia Patricia Diaz Guillen (“Diaz”) and Alejandro Jose Andrade Cedeno (“Andrade”) – who authorized a Venezuelan businessman named Raul Antonio Gorrin Belisario (“Gorrin”) to convert Venezuelan bolivars into U.S. dollars at highly favorable exchange rates at currency exchange houses under his control.  Gorrin then shared the resulting excess currency conversion profits with Diaz and Andrade by engaging in deceptive practices to purchase a wide variety of properties, aircraft and other luxury assets on behalf of Diaz, Andrade, their family members and their other business associates.  The Treasury Department published a diagram which explains the scheme in further detail.
Continue Reading