On January 15, 2021, the Department of Commerce’s Bureau of Industry and Security (BIS) issued an interim final rule implementing further provisions of the Export Control Reform Act of 2018 by: (i) imposing additional export license requirements under the Export Administration Regulations (EAR) in connection with certain military-intelligence end uses and end users; (ii) clarifying
Venezuela
OFAC Sanctions Individuals, Entities and Vessels Involved in Venezuelan Oil Sector
On January 19, 2021, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned and placed on the Specially Designated Nationals (SDN) List three individuals, fourteen entities, and six vessels for their involvement in a network attempting to evade U.S. sanctions on Venezuela’s oil sector. According to a press release, the “illegitimate…
OFAC Once Again Issues License Delaying PdVSA 2020 8.5% Bond-Related Authorizations
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that it has issued General License (GL) 5F (Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After July 21, 2021), which continues to delay U.S. persons’ ability to enforce bondholder rights to the CITGO…
Commerce Issues Military End User List for Exports to China and Russia
On December 23, 2020, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Federal Register notice in which it amends the Export Administration Regulations (EAR) by adding a new Military End User (MEU) List. This list identifies entities that BIS has determined are military end users for purposes of the “military end…
OFAC Sanctions China National Electronics Import and Export Corporation (CEIEC)
On November 30, 2020, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned and placed on the Specially Designated Nationals (SDN) List China National Electronics Import and Export Corporation (CEIEC). The Treasury Department indicated in a press release that this designation was due to CEIEC’s support for “the illegitimate Maduro regime’s efforts…
BIS Draft Rule Reportedly Lists, and May Further Restrict Exports with, Chinese and Russian Companies with Military Connections
In an early confidential draft of a proposed rule that BIS has shared with a technical advisory committee of industry representatives, trade press is reporting that the Department of Commerce’s Bureau of Industry and Security (BIS) may seek to restrict export transactions with 89 Chinese and 28 Russian companies that are owned or controlled by…
OFAC Issues Venezuela General License No. 8G to Continue Authorization of Limited Transactions Involving PdVSA and Winding Down of Operations for Certain Entities
On November 17, 2020, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 8G, “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…
Commerce Further Revises License Review Policy for Certain Exports to China, Russia and Venezuela
On October 29, 2020, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Federal Register notice announcing further amendments to the Export Administration Regulations (EAR) to revise the license review policy for items controlled for national security reasons destined to the People’s Republic of China (PRC), Venezuela or the Russian Federation (Russia).…
OFAC Again Issues License Delaying PdVSA 2020 8.5% Bond-Related Authorizations
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that it has issued General License (GL) 5E (Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After January 19, 2021), which continues to delay U.S. persons’ ability to enforce bondholder rights to the CITGO…
OFAC Issues License Delaying PdVSA 2020 8.5% Bond-Related Authorizations
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that it has issued General License (“GL”) 5D (Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After October 20, 2020), which continues to delay U.S. persons’ ability to enforce bondholder rights to the CITGO…