Sanctions

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On August 9, 2021, the White House issued a new Executive Order (EO), “Blocking Property of Additional Persons Contributing to the Situation in Belarus,” which expands existing U.S. sanctions against Belarus to target various sectors. The Treasury Department’s Office of Foreign Assets Control (OFAC) also issued a host of new designations to the Specially Designated…

On July 22 and again on July 30, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned several Cuban individuals and entities in connection with actions to suppress peaceful, pro-democratic protests in Cuba that began on July 11, 2021. According to Treasury Secretary Janet Yellen, “The Cuban people are protesting…

Key Notes:

  • On July 13, the U.S. government released an updated version of the Xinjiang Supply Chain Business Advisory advising U.S. companies of the widespread, PRC-government sponsored forced labor and intrusive surveillance practices targeting ethnic and religious minorities in Xinjiang.
  • The Advisory urges U.S. companies with supply chains, ventures or investments connected to Xinjiang to

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On July 23, 2021, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a settlement agreement with Payoneer Inc. (“Payoneer”), a publicly traded New York-based online money transmitter and provider of prepaid access.  Payoneer agreed to pay a civil penalty of approximately $1.4 million to settle its potential liability for 2,260 apparent…

On July 20, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that it has issued General License (GL) 5G, “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After October 21, 2021,” which continues to delay U.S. persons’ ability to enforce…

On July 16, 2021, the U.S. Departments of State, Commerce, Homeland Security and the Treasury issued a Hong Kong Business Advisory highlighting growing risks for U.S. companies operating in the Hong Kong Special Administrative Region (SAR) due to ongoing actions taken by the Government of the People’s Republic of China (China). The advisory states that…

On July 19, 2021, the Department of Commerce’s Bureau of Industry and Security (BIS) published a final rule adding six Russian entities to the Entity List after having been determined to be “acting contrary to the foreign policy interests of the United States.” The entities are:

  • Aktsionernoe Obshchestvo AST;
  • Aktsionernoe Obshchestvo Pasit;
  • Aktsionernoe Obshchestvo Pozitiv

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On July 12, 2021, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 40, “Authorizing Certain Transactions Involving the Exportation or Reexportation of Liquefied Petroleum Gas to Venezuela.”  This general license authorizes all transactions and activities related to the exportation or reexportation, directly or indirectly, of liquefied petroleum…

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has issued a final rule to remove the International Criminal Court-Related Sanctions Regulations, 31 C.F.R. part 520, from the Code of Federal Regulations. OFAC is taking this action after the national emergency upon which these sanctions were based was terminated by President  Biden…

On June 21, 2021, the Office of Foreign Assets Control (OFAC) designated 16 individuals and five entities in response to the Lukashenko regime’s escalating violence and repression. The persons are all closely associated with Belarusian President Alexander Lukashenko and, according to an OFAC press statement, “have harmed the people of Belarus through their activities…