On June 17, 2021, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued three general licenses related to the sanctions programs of Iran (General License N), Syria (General License 21) and Venezuela (General License 39), “Authorizing Certain Activities to Respond to the Coronavirus Disease 2019 (COVID-19)
Sanctions
Biden Administration Expands Sanctions on Chinese Military-Industrial Complex Companies
On June 3, 2021, President Biden issued Executive Order 14032, “Addressing the Threat from Securities Investments that Finance Certain Companies of the People’s Republic of China” (EO). The EO supersedes the executive orders targeting “Communist Chinese Military Companies” that the Trump administration issued. Specifically, it revises Sections 1 through 5 of Executive Order 13959…
OFAC Again Issues Venezuela General License to Continue Authorization of Limited Transactions Involving PdVSA and Winding Down of Operations for Certain Entities
On June 1, 2021, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 8H, “Authorizing Transactions Involving Petróleos de Venezuela, S.A. (PdVSA) Necessary for the Limited Maintenance of Essential Operations in Venezuela or the Wind Down of Operations in Venezuela for Certain Entities.” This general license continues to…
OFAC Publishes Formal Burma Sanctions Regulations
The Department of the Treasury’s Office of Foreign Assets Control (OFAC) has formally issued the Burma Sanctions Regulations to implement Executive Order 14014 of February 10, 2021, “Blocking Property With Respect to the Situation in Burma.” See SmarTrade Update of February 11, 2021. These regulations took effect on June 1, 2021, and are now…
Money Transfer Services Company Settles with OFAC for Apparent Violations of Sanctions Programs
On April 29, 2021, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a settlement with MoneyGram Payment Systems, Inc. (MoneyGram), a global payments and money transfer company. Under the settlement, MoneyGram agreed to pay a $34,000 civil penalty for 359 apparent violations of multiple OFAC sanctions programs. MoneyGram provided services to…
OFAC Reissues Amended Somalia Sanctions Regulations
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a final rule amending the Somalia Sanctions Regulations, 31 C.F.R. Part 551 (“Regulations”) and reissuing them to further implement the April 12, 2010 and July 20, 2012 Somalia-related executive orders. This final rule replaces the regulations that were published in abbreviated form…
OFAC Issues General License for Winding Down Transactions Involving Certain Belarus Companies
On April 19, 2021, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License No. 2H under the Belarus Sanctions Regulations, representing a shift in the licensing policy for transactions with certain entities. Since October 2015, now revoked OFAC General License No. 2G had authorized transactions with these nine companies. The…
OFAC Imposes New Sanctions on Russia’s Technology, Defense and Financial Sectors
On April 15, 2021, President Biden issued an Executive Order (“E.O.”) on “Blocking Property with Respect to Specified Harmful Foreign Activities of the Government of the Russian Federation.” The E.O. establishes a new national emergency under which sanctions may be imposed against individuals and entities furthering specified harmful foreign activities of Russia against the United…
DDTC Issues Guidance Regarding Restrictions on Exports to Russia
On April 12, 2021, the State Department’s Directorate of Defense Trade Controls (DDTC) issued additional guidance regarding changes that have been made to the International Traffic in Arms Regulations (ITAR) pertaining to export of defense articles or services to Russia. The guidance summarizes changes that were implemented on March 18, 2021, when the Departments of…
President Biden Terminates U.S. Sanctions Related to the International Criminal Court
On April 2, 2021, President Joseph Biden issued an Executive Order terminating a previously declared national emergency and related sanctions against certain persons involved with the International Criminal Court (ICC). In June 2020, President Trump issued Executive Order 13928 declaring a national emergency due to the ICC’s “illegitimate assertions of jurisdiction over personnel of the…
