• On May 15, 2019, President Trump issued a long-awaited E.O. designed to curtail the use of telecommunications items and services from certain countries and persons in U.S. networks. The E.O. does not impose immediate...more
5/16/2019
/ CFIUS ,
China ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Policy ,
Infrastructure ,
International Emergency Economic Powers Act (IEEPA) ,
Jurisdiction ,
National Security ,
New Regulations ,
Telecommunications ,
Trade Relations ,
Trump Administration
• OFAC recently added a Moscow-based Russian-Venezuelan joint venture bank, Evrofinance Mosnarbank (“Evrofinance”), to the List of Specially Designated Nationals and Blocked Persons (the “SDN List”) for engaging in sanctions...more
3/29/2019
/ Banking Sector ,
Blocked Person ,
Economic Sanctions ,
Financial Institutions ,
Foreign Policy ,
General Licenses ,
Joint Venture ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
SDN List ,
Trump Administration ,
Venezuela
• On January 28, 2019, OFAC added the Venezuelan state-owned oil and natural gas company PdVSA to its SDN List.
• As a result, U.S. persons are generally prohibited from engaging in transactions with PdVSA and entities that...more
2/6/2019
/ Blocked Person ,
Bonds ,
Capital Markets ,
Debt-Equity ,
Economic Sanctions ,
Energy Sector ,
Executive Orders ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
SDN List ,
Securities Transactions ,
State-Owned Enterprises ,
Trump Administration ,
Venezuela
• On September 20, 2018, for the first time, the Trump administration imposed sanctions on a non-U.S. entity and its director for engaging in “significant transactions” with a Russian defense sector company included on the...more
9/26/2018
/ Blocked Person ,
CAATSA ,
Defense Sector ,
Economic Sanctions ,
Executive Orders ,
Intelligence Services ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Secondary Sanctions ,
Suppliers ,
Trump Administration
• On August 6, 2018, following President Trump’s decision to withdraw the United States from the JCPOA, the U.S. government announced the reimposition of sanctions on Iran’s automotive sector, its trade in gold and precious...more
8/17/2018
/ Blocking Statutes ,
Economic Sanctions ,
EU ,
Executive Orders ,
International Relations ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Secondary Sanctions ,
Trade Relations ,
Trump Administration ,
Winding Down ,
Withdrawal
• On May 22, 2018, OFAC issued General License 15, authorizing U.S. persons to engage in specified transactions related to maintenance or wind-down of operations, contracts or other agreements involving GAZ Group or any...more
• On May 21, 2018, the Trump administration imposed new sanctions on the Government of Venezuela in response to the reelection of President Maduro and the “deepening humanitarian and public health crisis” fueled by the Maduro...more
• The U.S. government has withdrawn from the Iran Nuclear Deal and reverted sanctions to the status quo ante by re-imposing secondary sanctions that restrict non-U.S. persons from engaging in a broad range of business in...more
5/10/2018
/ Controlled Foreign Corporations ,
Economic Sanctions ,
Exports ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Trade Policy ,
Trump Administration
• On May 1, 2018, OFAC issued General License 13A authorizing the divestment or transfer of certain debt, equity or other holdings issued by EN+ Group, GAZ Group or United Company RUSAL PLC, as well as entities in which such...more
• On April 6, 2018, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) placed seven prominent Russian businessmen, 12 companies, 17 senior Russian government officials, and a state-owned Russian...more
4/9/2018
/ Banking Sector ,
Blocked Person ,
CAATSA ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
General Licenses ,
Government Officials ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
State-Owned Enterprises ,
Trump Administration ,
U.S. Treasury
On January 12, 2018, the U.S. administration took three actions relating to Iran -
• First, President Trump waived again the application of certain nuclear sanctions while making clear that the United States will refuse to...more
• Effective October 13, 2017, President Trump declined to provide certification that the JCPOA is in the United States’ national interest. Following this “decertification,” the U.S. Congress has 60 days in which to introduce...more
11/2/2017
/ Anti-Terrorism Financing ,
Decertify ,
Economic Sanctions ,
Executive Orders ,
Foreign Policy ,
Foreign Relations ,
Iran ,
Iran Nuclear Agreement Review Act of 2015 (INARA) ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Legislative Amendments ,
Members of Congress ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
Proposed Legislation ,
SDN List ,
Sunset Provisions ,
Trump Administration ,
U.S. Treasury
• On October 27, 2017, the U.S. State Department issued guidance identifying 39 entities related to the defense and intelligence sectors of the Government of the Russian Federation and issued related guidance on criteria to...more
10/31/2017
/ Defense Sector ,
Economic Sanctions ,
Export-Import Bank of the US ,
Exports ,
Extraterritoriality Rules ,
Financial Institutions ,
Foreign Exchanges ,
National Intelligence Agencies ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Secretary of the Treasury ,
State-Owned Enterprises ,
Trump Administration ,
US State Departments
Based on certain State Department findings, effective October 12, 2017, long-standing U.S. sanctions on the Republic of Sudan administered by OFAC under the Sudan Sanctions Regulations will be terminated, and U.S. persons...more
10/13/2017
/ Bureau of Industry and Security (BIS) ,
Commerce Control List ,
Commodities ,
Department of Defense (DOD) ,
Economic Sanctions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Exports ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Secretary of State ,
Sudan ,
Trade Restrictions ,
Trump Administration ,
TSRA
On September 29, 2017, OFAC modified Directives 1 and 2 of Executive Order 13662 to reduce the permissible maturity for new debt issued by Russian financial and energy entities designated under these directives, as well as...more
10/5/2017
/ Banking Sector ,
Cybersecurity ,
Debt ,
Economic Sanctions ,
Energy Sector ,
Executive Orders ,
Foreign Financial Institutions (FFI) ,
Foreign Relations ,
Office of Foreign Assets Control (OFAC) ,
Presidential Directives ,
Russia ,
Trump Administration ,
Ukraine
On September 21, 2017, the White House announced additional sanctions against North Korea, following a new round of sanctions imposed by the United Nations on September 11 and an escalation of U.S. sanctions previously...more
9/26/2017
/ Aircraft ,
Anti-Terrorism Financing ,
Economic Sanctions ,
Executive Orders ,
Exports ,
Foreign Financial Institutions (FFI) ,
Foreign Relations ,
Fund Transfers ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Secretary of State ,
Secretary of the Treasury ,
Trade Restrictions ,
Trump Administration ,
Vessels
On August 25, 2017, President Trump issued an Executive Order (EO) imposing economic sanctions related to Venezuela. The new measures prohibit U.S. persons from engaging in certain debt-, equity-, and securities-related...more
8/31/2017
/ Agricultural Sector ,
Blocked Person ,
Bonds ,
Citgo ,
Debt-Equity ,
Dividends ,
Economic Sanctions ,
Executive Orders ,
General Licenses ,
Medical Devices ,
Office of Foreign Assets Control (OFAC) ,
Patented Medicines ,
SDN List ,
Securities Transactions ,
Trump Administration ,
Venezuela
On August 2, 2017, President Trump signed into law the Countering America’s Adversaries Through Sanctions Act of 2017 (Pub. Law. No. 115-44, H.R. 3364) (the “Act”), which significantly expands economic sanctions against...more
8/9/2017
/ Anti-Corruption ,
Anti-Terrorism Financing ,
Arms Embargo ,
Congressional Override ,
Cyber Sanctions ,
Economic Sanctions ,
Executive Orders ,
Exports ,
Foreign Financial Institutions (FFI) ,
Foreign Relations ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
North Korea ,
Oil & Gas ,
Pipelines ,
Privatization ,
Russia ,
SDN List ,
SSI List ,
State-Owned Enterprises ,
Syria ,
Trade Restrictions ,
Trump Administration
On June 16, 2017, the Trump administration issued a national security presidential memorandum entitled “Strengthening the Policy of the United States Towards Cuba” (the “Presidential Memorandum”). Related to this...more
6/21/2017
/ Bureau of Industry and Security (BIS) ,
Business Licenses ,
Cuba ,
Department of Transportation (DOT) ,
Economic Sanctions ,
Financial Transactions ,
Internet ,
Obama Administration ,
Office of Foreign Assets Control (OFAC) ,
Presidential Memorandum ,
Tourism ,
Travel Restrictions ,
Trump Administration
Key Points -
- The U.S. Department of the Treasury’s Office of Foreign Assets Control has added 25 new entities and individuals to its Specially Designated Nationals List, including some located in China, Lebanon,...more