Sanctions

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On May 27, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 8J, extending authorization until December 1 for certain activities previously authorized under General License 8I. General License 8J authorizes the continuation of transactions and activities “ordinarily incident and necessary to the limited maintenance of essential…

On May 23, 2022, the U.S. Departments of State, the Treasury, Commerce, and Labor issued a joint advisory for U.S. businesses operating in Sudan. The advisory highlights the risks associated with conducting business with Sudan’s state-owned enterprises (“SOEs”), which are effectively controlled by the Sudanese military since its seizure of power on October 25, 2021.…

On May 12, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Syria General License (GL) 22, which authorizes certain transactions, including processing or transfer of funds on behalf of third-country entities, otherwise prohibited under the Syrian Sanctions Regulations (SSR) that are ordinarily incident and necessary to activities in the…

The Department of the Treasury’s Office of Foreign Assets Control (OFAC) recently issued several Russia-related general licenses under the Russian Harmful Foreign Activities Sanctions Regulations, 31 C.F.R. Part 587 (RuHSR). These licenses authorize certain activities which would otherwise be prohibited under OFAC sanctions toward Russia:

GL 26A extends until July 12, 2022 existing authorizations for…

Key Notes:

  • Persons, including non-U.S. persons, providing accounting, trust and corporate formation, and management consulting services in Russia may be added to the SDN List.
  • U.S. persons are prohibited from providing these same services to Russian persons unless the recipient of the services is the subsidiary of a U.S. person.

The Department of the Treasury’s…

On May 5, 2022, the Treasury Department’s Office of Foreign Assets Control (OFAC) issued much anticipated Russia-related general license (GL) 31, “Authorizing Certain Transactions Related to Patents, Trademarks, and Copyrights.” GL 31 authorizes certain transactions otherwise prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR Part 587 (“RuHSR”) with respect to intellectual…

On May 8, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) implemented additional sanctions on several sectors of the Russian economy.  OFAC designated three Russian telecommunications companies and placed them on the Specially Designated Nationals (SDN) list, noting that they are Russian state-controlled television stations generating revenue for the Russian government. …

The Department of Commerce’s Bureau of Industry and Security (BIS) issued on May 9, 2022, a Final Rule that greatly expands the list of items requiring a license to export to Russia. The export restrictions impact a broad range of inputs and products including wood products, industrial engines, boilers, motors, fans, and ventilation equipment, bulldozers,…

On May 2, 2022, new amendments to the Ukraine Related Sanctions Regulations, renaming them “Ukraine-/Russia-Related Sanctions Regulations” (URSR), were published by U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) in the Federal Register. The Ukraine-/Russia-Related Sanctions Regulations went into effect May 2.

OFAC’s new URSR replace the Ukraine Related Sanctions Regulations that were…

On May 3, 2022, the Securities and Exchange Commission’s Division of Corporation Finance issued a sample comment letter outlining public company disclosure requirements relating to the business impact of Russia’s invasion of Ukraine and the international response.

To the extent material or otherwise required under the SEC’s disclosure framework, the SEC advises that companies should…