On March 24, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela General License (GL) 41B extending the expiration date of Venezuela GL 41, which authorized certain transactions related to Chevron Corporation’s joint ventures in Venezuela. Previously, under GL 41A issued earlier this month, all transactions “ordinarily incident and
Sanctions
OFAC Once Again Extends Venezuela General License Delaying PdVSA 2020 8.5% Bond-Related Authorizations
On March 6, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 5R, “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After July 3, 2025,” which continues to delay U.S. persons’ ability to enforce bondholder rights to the CITGO…
Reversing the Biden Administration, OFAC Announces the Wind Down of Venezuela General License 41
On March 4, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License 41A within its Venezuela-Related Sanctions Program: “Authorizing the Wind Down of Certain Transactions Related to Chevron Corporation’s Joint Ventures in Venezuela.” The Biden Administration had issued the precursor to General License (GL) 41A, GL 41…
Reversing the Biden Administration, State Department Recreates the Cuba Restricted List
On February 6, 2025, the State Department republished the “Cuba Restricted List” identifying entities and subentities that are under the control of, or act for or on behalf of, the Cuban military, intelligence, or security services or personnel. The Cuba Restricted List is significant because direct financial transactions with the enumerated entities and subentities are…
President Trump Issues Executive Order on Countering Iran’s Malign Influence
On February 4, 2025, President Donald Trump issued an Executive Order (EO) stating that Iran’s malign behavior and influence threaten the national interest of the United States and that it is “in the national interest to impose maximum pressure on the Iranian regime to end its nuclear threat, curtail its ballistic missile program, and stop…
President Trump Initiates Tariffs on Canada, Mexico and China Under the IEEPA – Tariffs on Mexico and Canada Suspended until March 4 but Tariffs on China Start February 4
UPDATE: On February 7, President Donald Trump issued an executive order (EO) addressing the additional duties placed on imports into the United States of products of China. The article below stated that use of duty-free de minimis treatment on imports for shipments under $800 was being removed for shipments from China. The president has since…
President Trump Removes West Bank-Related Sanctions
On January 24, 2025, President Donald Trump issued an Executive Order (EO) revoking numerous EOs and actions implemented during the administration of former President Joseph Biden. Included in this action was the revocation of Executive Order 14115 of February 1, 2024 (Imposing Certain Sanctions on Persons Undermining Peace, Security, and Stability in the West Bank)…
OFAC Takes Further Action on Russia’s Attempts to Evade U.S. Sanctions
The Department of the Treasury’s Office of Foreign Asset Controls (OFAC) has issued further sanctions (see also January 15, 2025 Thompson Hine Update) to address Russia’s continued efforts to evade U.S. sanctions. OFAC noted in a press release that this latest action “targets a sanctions evasion scheme established between actors in Russia and [China]…
Treasury and State Departments Further Increase Sanctions on Russia by Targeting Its Oil and Gas Production Sectors
On January 10, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) targeted significant entities involved in Russia’s oil production, maritime insurers, maritime oil tankers, and other entities and persons engaged in Russia’s energy sector. According to an OFAC press release, the sanctions block two major Russian oil producers, over 180…
OFAC Sanctions Venezuelan Officials Supporting Nicolas Maduro’s Regime
On January 10, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated and placed eight Venezuelan officials on the Specially Designated Nationals (SDN) List for “enabling Nicolas Maduro’s repression and subversion of democracy in Venezuela.” The individuals sanctioned include the president of Petroleos de Venezuela, S.A., (PdVSA), Venezuela’s state-owned oil company…