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.
OFAC Again Issues License Delaying PdVSA 2020 8.5% Bond-Related Authorizations
By Scott E. Diamond** on
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that it has issued General License (GL) 5E (Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After January 19, 2021), which continues to delay U.S. persons’ ability to enforce bondholder rights to the CITGO…
Treasury Department Issues Ransomware Advisories, Notes Facilitating Ransomware Payments May Violate the Law
By Scott E. Diamond** on
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…
OFAC Issues International Criminal Court-Related Sanctions Regulations; Lawsuit Seeks to Declare Executive Order and Regulations Unconstitutional
By Scott E. Diamond** on
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…
OFAC Sanctions Additional Syrian Officials and Entities for Continued Corruption and Human Rights Abuses
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…
OFAC Amends Cuba Sanctions, Further Restricting Activities with Cuba
By Scott E. Diamond** on
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;…
Departments of State and the Treasury Impose Additional Sanctions on Iran
By Scott E. Diamond** on
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…
Departments of Commerce, State and the Treasury Issue North Korea Ballistic Missile Procurement Advisory
By Scott E. Diamond** on
On September 1, 2020, the Department of State’s Bureau of International Security and Nonproliferation, the Department of the Treasury’s Office of Foreign Assets Control (OFAC), and the Department of Commerce’s Bureau of Industry and Security (BIS) issued a joint advisory to alert persons to the Democratic People’s Republic of Korea’s (North Korea) ballistic missile procurement…
Commerce and Treasury Departments Sanction Entities Supporting Iran’s Mahan Air
By Scott E. Diamond** on
The Department of Commerce’s Bureau of Industry and Security (BIS) and the Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions against several persons and entities determined to be supporting Iran’s Mahan Air in violation of U.S. sanctions toward Iran. According to both agencies, the involved companies have provided key parts and logistics services…
Treasury and State Departments Continue to Tighten Sanctions Against Syrian President Basher al-Assad’s Regime
By Scott E. Diamond** on
On August 20, 2020, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of State sanctioned six Syrian individuals in President Basher al-Assad’s office and the Syrian Ba’ath Party who have contributed to the oppression of the Assad regime. The sanctioned individuals are: (1) President al-Assad’s media adviser, Luna al…