On May 19, 2023, the Department of the Treasury issued a Determination pursuant to E.O. 14071 that prohibits the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a U.S. person, wherever located, of architecture or engineering services to any person located in the Russian Federation. The determination excludes the
Sanctions
OFAC Again Extends Venezuela General License for Limited Maintenance or Wind-Down of Transactions Involving PdVSA and Certain Entities
On May 23, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 8L, extending authorization until November 19, 2023 for certain activities previously authorized under General License 8K. General License 8L authorizes the continuation of transactions and activities “ordinarily incident and necessary to the limited maintenance of…
OFAC and State Department Designate and Sanction Over 225 Individuals and Entities Involved in Russia’s War Against Ukraine
On May 19, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of State sanctioned and placed on the Specially Designated Nationals (SDN) List over 225 individuals, entities, vessels and aircraft. These actions came at the same time the G7 member countries were meeting and jointly announced both continued…
BIS Issues Final Rules Implementing Additional Sanctions Against Russia and Belarus and Adding Entities to the Entity List
On May 19, 2023, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a significant Final Rule implementing additional sanctions and revising existing export controls against Russia and Belarus for ongoing aggression against Ukraine. According to the announcement, these revisions and additions seek to better align U.S. sanctions with the controls that have…
OFAC Amends Russia-Related Directive 4 Regarding Transactions with Russian Federation Central Bank and Other Entities
On May 19, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an amended Directive 4, “Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation.” The purpose of the amendment…
OFAC Again Extends Russia-Related General License No. 8 Regarding Transactions Related to Energy
On May 5, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued amended Russia-related General License No. 8G extending the authorization to conduct transactions involving Vnesheconombank, Bank Financial Corporation Otkritie, Sovcombank, Sberbank, VTB Bank, Alfa-Bank, Rosbank, Bank Zenit, Bank Saint-Petersburg, and the Central Bank of Russia that are related to energy…
President Biden Introduces New Sudan-Related Sanctions
On May 4, 2023, President Biden signed a new Executive Order, Imposing Sanctions on Certain Persons Destabilizing Sudan and Undermining the Goal of a Democratic Transition, stating that the violence taking place in Sudan “is a tragedy” and “must end.”
Finding that the situation in Sudan constitutes an extraordinary threat to U.S. national security…
Deputies of the G7 Enforcement Coordination Mechanism Discuss Russia Sanctions Evasion
On April 27, 2023, deputies of the Group of Seven (G7) Enforcement Coordination Mechanism met to discuss the need to increase enforcement of multilateral sanctions and export controls implemented since Russia’s invasion of Ukraine in February 2022 in order to deny Russia access to the materials it requires to equip its military and the revenue…
OFAC Again Revises Venezuela General License Extending Delay of PdVSA 2020 8.5% Bond-Related Authorizations
On April 19, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 5K, “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After July 20, 2023,” which continues to delay U.S. persons’ ability to enforce bondholder rights to the CITGO…
OFAC and State Department Continue to Target Individuals and Entities Facilitating Russian Financial Transactions and Supporting Russia’s Defense Sector
On April 12, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced further efforts to deny Russia’s access to the international financial system through facilitators and their businesses. For example, OFAC has designated and sanctioned the “facilitation network” of Alisher Burhanovich Usmanov, who had previously been placed on OFAC’s Specially Designated…