On January 28, 2019, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated Petróleos de Venezuela, S.A. (PdVSA) pursuant to Executive Order (E.O.) 13850 – “Blocking Property of Additional Persons Contributing to the Situation in Venezuela”. Further, OFAC amended General License 3, issued eight (8) new General Licenses, and published a
New Law Puts Nicaragua in the Cross-Hairs of Potential U.S. Financial Restrictions and Possible Additional Sanctions
On December 20, 2018, President Trump signed into law the Nicaragua Human Rights and Anticorruption Act of 2018 (NICA Act). The sanctions listed in the NICA Act are additional and would be complementary to the current sanctions that have already been imposed on Nicaragua by the US Office of Foreign Assets Control (OFAC).
United States Reinstates Full Iran Embargo
On November 5, 2018, in accordance with President Trump’s May 8, 2018 decision to withdraw from the Joint Comprehensive Plan of Action (JCPOA), the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) issued an amendment to the Iranian Transactions and Sanctions Regulations (ITSR). The amendment followed on the expiration of the final 180-day
Forced Labor: The Interplay Between Sanctions and Customs Compliance in the Context of the Democratic People’s Republic of Korea (DPRK)
As a consequence of U.S. and UN sanctions on the Democratic People’s Republic of Korea (DPRK or North Korea), companies increasingly need to coordinate compliance efforts across the typically distinct worlds of economic sanctions and import/customs compliance. This is particularly necessary with respect to identifying, and mitigating the risk of DPRK-related labor in supply
OFAC Extends Divestment and Transfer Period for Certain Russian Companies to Oct 23
On July 31, 2018, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Ukraine-/Russia-related General License 13C, which replaces and supersedes General License 13B in its entirety.
General License 13C extends to 12:01 a.m. October 23, 2018, the “authorized period to make certain divestment and transfer activities related to debt, equity,
OFAC Issues Venezuela General License 5 and Venezuela-related Frequently Asked Questions
On July 19, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela General License 5.
General License 5 authorizes U.S. persons to engage in all transactions related to, the provision of financing for, and other dealings in the Petróleos de Venezuela SA 2020 8.5 Percent Bond that would be prohibited
OFAC Revokes Several Iran-Related Licenses To Begin The Process Of Re-Imposing Certain Iran-Related Sanctions Post-JCPOA
On June 27, in accordance with President Trump’s May 8, 2018 decision to withdraw from the Joint Comprehensive Plan of Action (JCPOA), the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) revoked two Iran-related General Licenses and amended the Iranian Transactions and Sanctions Regulations (ITSR), 31 C.F.R. part 560, to reflect the
Wind Down Period for Some Russian Companies Extended in New OFAC General License
On June 4, 2018, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Ukraine-/Russia-related General License 16 (GL16).
General License 16 authorizes U.S. persons to engage in specified transactions related to winding down or maintaining business involving EN+ Group PLC, JSC EuroSibEnergo, or any entity in which EN+ Group PLC or JSC
U.S. Targets Gov’t of Venezuela and PDVSA with New Factoring Sanctions
On May 21, President Trump issued a new Executive Order (E.O.) “Prohibiting Certain Additional Transactions with Respect to Venezuela.” The new E.O. targets the Venezuelan Government’s ability to factor receivables and liquidate equity interest in exchange for cash.
The E.O. prohibits U.S. persons or persons within the United States from all transactions related
EU Announces Plans to Mitigate the Impact of U.S. Sanctions on Iran
On May 18, the EU Commission announced plans to protect EU companies doing business in Iran. This announcement comes in response to President Trump’s decision to withdraw from the Joint Comprehensive Plan of Action (JCPOA), known as the Iran nuclear deal, and re-impose U.S. sanctions on Iran. The EU Commission plans to mitigate the extraterritorial