On February 1, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) published an Oil Price Cap Compliance and Enforcement Alert to provide “[a]n overview of [five] key … evasion methods and [corresponding] recommendations for identifying such methods and [subsequently] mitigating their risks and negative impacts.” The price cap referenced by the
U.S. Announces New Sanctions to Promote Peace, Security, and Stability in the West Bank
On February 1, 2024, the United States introduced new sanctions to promote peace in the West Bank, targeting recent actions that jeopardize the region’s stability, including attacks by Israeli settlers against Palestinians and Palestinian attacks against Israelis. This follows the related visa restriction policy announced by the State Department on December 5, 2023.
The sanctions have
U.S. Re-Designates Ansarallah (aka the Houthis) as a Global Terrorist Group
On January 17, 2024, the Department of State announced that it was re-designating Yemen-based Ansarallah, commonly referred to as the Houthis, as a Specially Designated Global Terrorist (SDGT) group. This designation will be effective as of February 16, 2024, when Ansarallah will be placed on the Department of the Treasury’s Office of Foreign Assets Control (OFAC)
OFAC Continues to Extend Venezuela General License Delaying PdVSA 2020 8.5% Bond-Related Authorizations
On January 16, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 5N, “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After April 16, 2024,” which continues to delay U.S. persons’ ability to enforce bondholder rights to the CITGO
OFAC Updates its Guidance on the Price Caps on Russian Oil and Russian Petroleum Products
On December 20, 2023, nearly eleven months after publishing its finalized guidance on the implementation of the twin price caps on Russian oil and Russian petroleum products, the Department of the Treasury (“Treasury”) published a revised Guidance on Implementation of the Price Cap Policy for Crude Oil and Petroleum Products of Russian Federation Origin.
President Biden Authorizes Secondary Sanctions on Foreign Financial Institutions Facilitating Certain Transactions Involving Russia
On December 22, 2023, President Joseph Biden issued Executive Order 14114 (EO) amending EO 14024 by authorizing the imposition of U.S. sanctions on foreign financial institutions that are either facilitating significant transactions on behalf of persons designated for operating in certain key sectors of the Russian economy, or facilitating significant transactions or providing services involving Russia’s
President Biden Expands U.S. Sanctions on Russia by Authorizing Additional Prohibitions on Imports of Russian Seafood and Diamonds
On December 22, 2023, President Joseph Biden amended, among other things, Executive Order (EO) 14068, by additionally authorizing the prohibition on the importation and entry into the United States, including a foreign trade zone located in the United States, of the following products of Russian Federation origin: fish, seafood, and preparations thereof, as well
OFAC and State Sanction Over 250 Entities and Individuals in Connection with Russia’s War Against Ukraine
On December 12, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of State announced sanctions designating numerous additional Russian individuals and entities who have been determined to be assisting in the war against Ukraine and for efforts to evade U.S. sanctions and export controls on Russia. OFAC also
OFAC and BIS Further Sanction Belarusian and Russian Entities and Individuals
On December 5, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of Commerce’s Bureau of Industry and Security (BIS) imposed sanctions on numerous entities and individuals in order to place additional pressure on both Belarus and Russia. The OFAC sanctions focus on Belarus’ “authoritarian regime” and for its
OFAC Once Again Extends Venezuela General License for Limited Maintenance or Wind-Down of Transactions Involving PdVSA and Certain Entities
On November 16, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 8M, extending authorization until May 16, 2024 for certain activities previously authorized under General License 8L. General License 8M authorizes the continuation of transactions and activities “ordinarily incident and necessary to the limited maintenance of