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On November 7, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 8O︎, extending authorization until May 9, 2025 for certain activities previously authorized under General License 8N. General License 8O︎ authorizes the continuation of transactions and activities “ordinarily incident and necessary to the limited maintenance of essential…

On November 7, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 5Q, “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After March 7, 2025,” which continues to delay U.S. persons’ ability to enforce bondholder rights to the CITGO…

On October 30, 2024, the Departments of the Treasury, State and Commerce undertook further sanctions against “enablers of Russia’s military-industrial base.” In total, the actions taken by the Office of Foreign Assets Control (OFAC) and the Bureau of Industry and Security (BIS) sanction over 300 individuals and entities involved in supplying Russia with advanced technology…

On October 11, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that it was expanding sanctions on Iran’s petroleum and petrochemical sectors in response to Iran’s October 1 attack on Israel. The Secretary of the Treasury has identified the petroleum and petrochemical sectors of the Iranian economy pursuant to a…

On September 30, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) again extended previous Russia-related General License (GL) 13 by issuing a revised GL 13K, “Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024,” which states that U.S. persons are authorized to pay taxes, fees, or import…

On September 13, 2024, the United States designated and placed on the Department of the Treasury’s Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) List three entities and two individuals for their connection to Russia’s destabilizing actions abroad, particularly efforts to undermine and manipulate the outcome of the October 2024 Moldovan presidential election.

The Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a final rule on Updating Provisions Related to Blocking and Other Actions Related to Specific Property or Interests in Property. The rule is effective as of September 17, 2024.

The new rule aims to clarify OFAC’s process for issuing orders that block…

All U.S. persons and persons otherwise subject to U.S. jurisdiction, not only U.S. financial institutions, holding property blocked pursuant to various Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctions programs must file their Annual Report of Blocked Property (ARBP) by September 30, 2024.

This report is pursuant to 31 C.F.R. §§ 501.603…

On September 11, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) published an Interim Final Rule to amend its Reporting, Procedures and Penalties Regulations under 31 C.F.R. Part 501, which extends recordkeeping requirements for certain transactions from 5 years to 10 years.  This Interim Final Rule takes effect on March 12…

On September 4, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a revised Russia General License (GL) 25E that continues to authorize all transactions ordinarily incident and necessary to the receipt or transmission of telecommunications involving the Russian Federation. This continues to allow for services incident to the exchange of…