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On November 30, 2020, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned and placed on the Specially Designated Nationals (SDN) List China National Electronics Import and Export Corporation (CEIEC). The Treasury Department indicated in a press release that this designation was due to CEIEC’s support for “the illegitimate Maduro regime’s efforts…

On November 17, 2020, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 8G, “Authorizing Transactions Involving Petróleos de Venezuela, S.A. (PdVSA) Necessary for the Limited Maintenance of Essential Operations in Venezuela or the Wind Down of Operations in Venezuela for Certain Entities.”  This general license continues to…

On October 27, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published a final rule in the Federal Register amending the Cuban Assets Control Regulations (CACR) to remove from the scope of generally authorized remittances any transactions involving “entities or subentities” identified on the U.S. Department of State’s Cuba Restricted…

On October 14, 2020, pursuant to the Hong Kong Autonomy Act (HKAA), the State Department submitted to Congress a report identifying foreign persons “who are materially contributing to, have materially contributed to, or attempt to materially contribute to the failure of the People’s Republic of China (China) to meet its obligations under the Sino-British Joint…

On October 8, 2020, the Departments of State and the Treasury announced sanctions on numerous Iranian financial institutions. The Department of the Treasury’s Office of Foreign Assets Control (OFAC) has sanctioned eighteen major Iranian banks. Secretary of the Treasury Steven Mnuchin stated that the sanctions “reflect our commitment to stop illicit access to U.S.…

On October 1, 2020, the Department of the Treasury issued two related advisories to assist U.S. companies in efforts to combat ransomware scams and attacks. In addition to offering guidance, the advisories note that anti-money laundering and economic sanctions regulations implemented and enforced by Treasury’s Office of Terrorism and Financial Intelligence may be triggered by…

In a series of actions this week, the Department of the Treasury moved to implement regulations to enforce sanctions related to actions of the International Criminal Court (ICC). Almost immediately, however, President Trump’s executive order and the regulations were challenged in court.

ICC-Related Executive Order and Regulations

On June 11, 2020, President Trump issued Executive…

On September 30, 2020, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned three Syrian individuals and 13 entities, placing them on the Specially Designated Nationals and Blocked Persons (SDN) List. These persons and entities are associated with the Fourth Division of the Syrian Arab Army, the Syrian General Intelligence Directorate and…

On September 24, 2020, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a Federal Register notice amending the Cuban Assets Control Regulations (CACR) in order “to further implement the President’s foreign policy to deny the Cuban regime sources of revenue.” The changes will restrict: (1) lodging at certain properties in Cuba;…

On September 3, 2020, the Department of State and the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned numerous entities and persons for their reported involvement with the petroleum or petroleum sector of Iran. According to a press statement from Secretary of State Michael Pompeo,  the targeted entities and persons have “continued…