On December 30, 2022, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published preliminary guidance on how the United States will implement a price cap policy on petroleum products of Russian origin. OFAC notes that with this preliminary guidance the agency will likely “take a similar approach for Russian petroleum products as
On December 19, 2022, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) introduced the first set of regulations to be issued under the new Illicit Drug Trade Sanctions (to be codified at 31 CFR part 599). The regulations will go into effect on December 20 pursuant to Executive Order (“E.O.”) 14059 (December
On December 15, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that it was adding Russian banks and financial services entities as well as additional Russian persons to the Specially Designated Nationals (SDN) List in order to further isolate Russia from global markets. For additional information on these entities and
On December 2, 2022, the Department of the Treasury (“Treasury”) issued a Determination pursuant to Executive Order 14071 of April 6, 2022 imposing a price cap of $60 per barrel on seaborne crude oil of Russian origin, effective December 5, 2022. Thus, companies can purchase and/or provide services related to the maritime transport of Russian-origin
On November 21, 2022, the Department of the Treasury issued a Determination pursuant to Executive Order 14071 (prohibiting new investment in and the provision of certain services to the Russian Federation, see Update of April 7, 2022), that prohibits the following categories of services related to the maritime transport of crude oil of Russian
On November 26, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela General License (GL) 41 authorizing all transactions ordinarily incident and necessary to certain activities for or related to the operation and management by Chevron Corporation or its subsidiaries (“Chevron”) of Chevron’s joint ventures in Venezuela (collectively, the “Chevron
On November 26, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 8K, extending authorization until May 26, 2023 for certain activities previously authorized under General License 8J. General License 8K authorizes the continuation of transactions and activities “ordinarily incident and necessary to the limited maintenance of
On November 10, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued amended Russia-related General License No. 8D extending the authorization to conduct transactions involving Vnesheconombank, Bank Financial Corporation Otkritie, Sberbank, VTB Bank, Alfa-Bank, and the Central Bank of Russia that are related to energy until May 15, 2023. The original
On October 14, 2022, the Departments of Commerce, Treasury and State issued a joint alert regarding the Impact of Sanctions and Export Controls on Russia’s Military-Industrial Complex. The alert provides a summary of the major actions taken by Treasury’s Office of Foreign Assets Control (OFAC) and Commerce’s Bureau of Industry and Security (BIS) with
On September 30, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated hundreds of Russian individuals and entities and placed them on the Specially Designated Nationals (SDN) List in response to Russia’s illegal annexation of additional Ukrainian territories.
The new designations target 14 suppliers connected to the country’s military-industrial complex, including