On July 20, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) implemented further sanctions against Russia to restrict “access to products that support its military and war efforts; reduce Russia’s revenue from the metals and mining sector; undermine its future energy capabilities; degrade Russia’s access to the international financial system; and
OFAC Again Revises Venezuela General License, Extending Delay of PdVSA 2020 8.5% Bond-Related Authorizations
On April 19, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 5L, “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After October 20, 2023,” which continues to delay U.S. persons’ ability to enforce bondholder rights to the CITGO
OFAC Issues General License 40B Continuing to Authorize Certain Transactions Involving the Export of LP Gas to Venezuela
On July 10, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 40B, “Authorizing Certain Transactions Involving the Exportation or Reexportation of Liquefied Petroleum Gas to Venezuela.” This revised general license continues authorization of all transactions and activities related to the exportation or reexportation, directly or indirectly
Five Eyes Partners Formalize Cooperation on Export Control Enforcement Efforts
On June 28, 2023, the Department of Commerce’s Bureau of Industry and Security (BIS) announced that the United States was joining its “Five Eye” partners – Australia, Canada, New Zealand, and the United Kingdom – in committing to formally coordinate on export control enforcement. While these allied countries have shared intelligence and other national security
FinCEN & BIS Issue Joint Alert Encouraging Continued Vigilance Regarding Potential Russia Export Control Evasion
Key Notes:
OFAC Issues New General Licenses Under Sudan-Related Sanctions
On June 1, 2023, the Office of Foreign Assets Control (OFAC) issued four new Sudan-related General Licenses authorizing certain transactions that would otherwise be prohibited by Executive Order (EO) 14098 dated May 4, 2023 (See Update of May 4, 2023):
- General License No. 1 authorizes transactions for the conduct of the official business
Treasury Issues Determinations on Prohibitions Related to Architecture, Engineering, Construction, Manufacturing, and Transportation Sectors in Russia
On May 19, 2023, the Department of the Treasury issued a Determination pursuant to E.O. 14071 that prohibits the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a U.S. person, wherever located, of architecture or engineering services to any person located in the Russian Federation. The determination excludes the
OFAC Again Extends Venezuela General License for Limited Maintenance or Wind-Down of Transactions Involving PdVSA and Certain Entities
On May 23, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 8L, extending authorization until November 19, 2023 for certain activities previously authorized under General License 8K. General License 8L authorizes the continuation of transactions and activities “ordinarily incident and necessary to the limited maintenance of
OFAC and State Department Designate and Sanction Over 225 Individuals and Entities Involved in Russia’s War Against Ukraine
On May 19, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of State sanctioned and placed on the Specially Designated Nationals (SDN) List over 225 individuals, entities, vessels and aircraft. These actions came at the same time the G7 member countries were meeting and jointly announced both continued
BIS Issues Final Rules Implementing Additional Sanctions Against Russia and Belarus and Adding Entities to the Entity List
On May 19, 2023, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a significant Final Rule implementing additional sanctions and revising existing export controls against Russia and Belarus for ongoing aggression against Ukraine. According to the announcement, these revisions and additions seek to better align U.S. sanctions with the controls that have