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)
Sanctions
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…
OFAC Issues Syria General License Addressing Sanctions Relief for Syrian People
On January 6, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Syria General License (GL) 24 to expand authorizations for activities and transactions in Syria following the events of December 8, 2024, and the removal of Bashar al-Assad from power. The intent of the GL is to ensure that U.S.
OFAC Continues to Extend Authorizations Under Russia General License 13
On January 7, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) again extended previous Russia-related General License (GL) 13 by issuing a revised GL 13L, “Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024,” which states that U.S. persons are authorized to pay taxes, fees, or import…
OFAC Issues General License Allowing Transactions Involving Gazprombank Related to Civil Nuclear Energy
On December 19, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Russia-related General License 115 to generally authorize transactions involving Gazprombank that are related to civil nuclear energy. After sanctioning Gazprombank in November 2024 in order to further limit Russia’s access the international financial system (see Thompson Hine Update…
OFAC Further Expands Sanctions on Iran for Missile Attack on Israel and Renewed Nuclear Escalations
On December 3, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that it was “intensifying pressure” on Iran’s petroleum and petrochemical sectors by imposing sanctions on 35 entities and vessels “that play a critical role in transporting illicit Iranian petroleum to foreign markets.” This action identifies and imposes further sanctions…
OFAC Sanctions Gazprombank and Further Limits Russia’s Access to International Financial System
On November 21, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated Gazprombank, more than 50 internationally connected small-to-medium Russian banks, more than 40 Russian securities registrars, and 15 Russian finance officials. Treasury Secretary Janet Yellen stated that these sanctions target “Russia’s largest remaining non-designated bank, as well as dozens of…
OFAC Continues to Extend Venezuela General License for Limited Maintenance or Wind-Down of Transactions Involving PdVSA and Certain Entities
By Scott E. Diamond** & Samir D. Varma on
On November 7, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 8O︎, extending authorization until May 9, 2025 for certain activities previously authorized under General License 8N. General License 8O︎ authorizes the continuation of transactions and activities “ordinarily incident and necessary to the limited maintenance of essential…