On February 3, 2023, the Department of the Treasury (Treasury) issued multiple determinations related to the price cap to be set on Russian-origin petroleum products. Treasury also published finalized guidance on the broader price cap policy implemented by the “Price Cap Coalition” – an international coalition that includes the United States, the G7, the European Union
OFAC Again Revises Venezuela General License Extending Delay of PdVSA 2020 8.5% Bond-Related Authorizations
On January 7, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 5J, “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After April 20, 2023,” which continues to delay U.S. persons’ ability to enforce bondholder rights to the CITGO
OFAC Publishes Preliminary Guidance on Price Cap to Be Placed on Petroleum Products of Russian Origin
On December 30, 2022, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published preliminary guidance on how the United States will implement a price cap policy on petroleum products of Russian origin. OFAC notes that with this preliminary guidance the agency will likely “take a similar approach for Russian petroleum products as
OFAC Publishes First Set of Sanctions Against Foreign Persons Involved in the Global Illicit Drug Trade
On December 19, 2022, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) introduced the first set of regulations to be issued under the new Illicit Drug Trade Sanctions (to be codified at 31 CFR part 599). The regulations will go into effect on December 20 pursuant to Executive Order (“E.O.”) 14059 (December
BIS Places More Russian Companies on Entity List and Sanctions Alleged Procurement Network
Effective December 16, 2022, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule announcing that it was moving nine Russian companies from the Unverified List to the more restrictive Entity List. BIS stated it has continuously been unable to verify the bona fides of these companies due to the Russian
OFAC Sanctions Additional Russian Financial Institutions and Persons
On December 15, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that it was adding Russian banks and financial services entities as well as additional Russian persons to the Specially Designated Nationals (SDN) List in order to further isolate Russia from global markets. For additional information on these entities and
Treasury Sanctions Network of Chinese Fishing Vessels for Serious Human Rights Abuses
On December 9, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned two Chinese individuals and a vast network fishing vessels they control, including Pingtan Marine Enterprise Ltd. (PME) and Dalian Ocean Fishing Co., Ltd. (Dalian), for perpetrating serious human rights abuses and corruption via illegal, unreported, and unregulated (IUU) fishing. Although
Treasury Announces Price Cap on Russian Oil
On December 2, 2022, the Department of the Treasury (“Treasury”) issued a Determination pursuant to Executive Order 14071 of April 6, 2022 imposing a price cap of $60 per barrel on seaborne crude oil of Russian origin, effective December 5, 2022. Thus, companies can purchase and/or provide services related to the maritime transport of Russian-origin
OFAC Issues General License Authorizing Chevron to Operate in Venezuela with PdVSA
On November 26, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela General License (GL) 41 authorizing all transactions ordinarily incident and necessary to certain activities for or related to the operation and management by Chevron Corporation or its subsidiaries (“Chevron”) of Chevron’s joint ventures in Venezuela (collectively, the “Chevron
OFAC Again Extends Venezuela General License for Limited Maintenance or Wind-Down of Transactions Involving PdVSA and Certain Entities
On November 26, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 8K, extending authorization until May 26, 2023 for certain activities previously authorized under General License 8J. General License 8K authorizes the continuation of transactions and activities “ordinarily incident and necessary to the limited maintenance of