On April 19, 2021, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License No. 2H under the Belarus Sanctions Regulations, representing a shift in the licensing policy for transactions with certain entities. Since October 2015, now revoked OFAC General License No. 2G had authorized transactions with these nine companies. The
OFAC Imposes New Sanctions on Russia’s Technology, Defense and Financial Sectors
By Scott E. Diamond** on
On April 15, 2021, President Biden issued an Executive Order (“E.O.”) on “Blocking Property with Respect to Specified Harmful Foreign Activities of the Government of the Russian Federation.” The E.O. establishes a new national emergency under which sanctions may be imposed against individuals and entities furthering specified harmful foreign activities of Russia against the United…
President Biden Terminates U.S. Sanctions Related to the International Criminal Court
By Scott E. Diamond** on
On April 2, 2021, President Joseph Biden issued an Executive Order terminating a previously declared national emergency and related sanctions against certain persons involved with the International Criminal Court (ICC). In June 2020, President Trump issued Executive Order 13928 declaring a national emergency due to the ICC’s “illegitimate assertions of jurisdiction over personnel of the…
State Department Issues Second Hong Kong Autonomy Report
By Scott E. Diamond** on
On March 16, 2021, the State Department identified 24 additional persons it determined are contributing to “the failure of the People’s Republic of China (PRC) to meet its obligations under the Sino – British Joint Declaration … or Hong Kong’s Basic Law” and, as a result, the Department of the Treasury has sanctioned these persons.…
Company Designated as a Communist Chinese Military Company Obtains Court Injunction on Investment Ban
By Scott E. Diamond** on
On March 12, 2021, the U.S. District Court for the District of Columbia issued a preliminary injunction which prohibits the Department of Defense (DOD) from enforcing its January 2021 designation of Xiaomi Corporation (Xiaomi) of China as a Communist Chinese Military Company (CCMC) pursuant to Executive Order (EO) 13959 and Section 1237 of the National…
OFAC and BitPay Enter into Settlement Agreement for Apparent Violations Related to Digital Currency Transactions
By Scott E. Diamond** on
On February 18, 2021, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) entered into a $507, 375 settlement with BitPay, Inc. (“BitPay”) for 2,102 apparent violations of multiple sanctions programs. BitPay, a cryptocurrency company offering payment processing solutions for merchants to accept digital currency as payment for goods and services, agreed to…
President Biden Issues Executive Order Sanctioning Burmese Military Leaders and Entities Involved in Coup
By Scott E. Diamond** on
President Biden Issues Executive Order Regarding Military Coup in Burma and Sanctioning Military Leaders
On February 10, 2021, President Joe Biden issued an Executive Order concerning the military coup in Burma on February 1, 2021, in which the military overthrew the democratically elected civilian government and arrested numerous government leaders, politicians, human rights defenders, journalists,…
OFAC Sanctions Individuals, Entities and Vessels Involved in Venezuelan Oil Sector
By Scott E. Diamond** on
On January 19, 2021, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned and placed on the Specially Designated Nationals (SDN) List three individuals, fourteen entities, and six vessels for their involvement in a network attempting to evade U.S. sanctions on Venezuela’s oil sector. According to a press release, the “illegitimate…
OFAC Publishes Formal Hong Kong Sanctions Regulations
By Scott E. Diamond** on
On January 15, 2021, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) published in the Federal Register final regulations to implement a July 14, 2020 Hong Kong-related Executive Order. In Executive Order 13936, President Donald Trump determined that Hong Kong was no longer sufficiently autonomous from the People’s Republic of China…
OFAC Issues Guidance Regarding Ban on Transacting in Securities of “Communist Chinese Military Companies”
Key Notes:
- The ban is effective January 11, 2021.
- Executive Order 13959 bans U.S. persons from transacting in publicly traded securities or derivatives or similar securities of publicly traded Chinese companies designated by the U.S. Department of Defense as enabling Chinese military aims.
- OFAC has identified, and will continue to add, subsidiaries of the named
…