On September 9, 2019, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued a new Venezuela-related general license (General License 34) to authorize transactions involving certain Government of Venezuela-related individuals that would otherwise be prohibited by Executive Order (“EO”) 13884.
On August 30, 2019, the US Commerce Department’s Bureau of Industry and Security (“BIS”) published Due Diligence Guidance urging companies to employ heightened due diligence when exporting to Pakistan (the “Pakistan Guidance”). The Pakistan Guidance specifically focuses on (i) supplemental licensing requirements applicable for items (e.g. goods, software, or technology) subject to the Export Administration Regulations (“EAR”) that may be destined to nuclear or missile activities, and (ii) best practices for screening customers in Pakistan to prevent diversion of items subject to the EAR to unauthorized end uses and end users.
BIS published the Pakistan Guidance in an effort to bring attention to compliance risks related exports/reexports to Pakistan after investigations by the BIS Office of Export Enforcement “revealed schemes” by Pakistani entities attempting to acquire items subject to the EAR for entities listed on the Entity List. The Pakistan Guidelines appear to reflect an enforcement focus on Pakistan from BIS, so companies exporting/reexporting items subject to the EAR to Pakistan should take into account these BIS recommendations to ensure compliance.
Key takeaways from the Pakistan Guidance are found below:Read more…
OFSI publish new links to the consolidated list
Today, the Office of Financial Sanctions Implementation (OFSI) have published new links to the consolidated list, the system it uses to publish the details of individuals and entities subject to financial sanctions. The current pages that contain the consolidated list will be removed.
In addition to the usual list which includes details of individuals and entities subject to financial sanctions, the consolidated list now includes a new search function. This will enable users to quickly and easily search the consolidated list to find asset freeze targets based on any of the identifying information from their listing.
The search tool can also use fuzzy logic to help provide direct and/or indirect results. This means the search can return results even where search terms are incorrectly spelt.
It is important that any bookmarks to the old pages are now updated to the new pages below:
List of asset-freeze targets
List of targets subject to restrictions on financial markets and services
Note on .xls format
Please note that the .xls format will be retired in the coming months and subscribers should arrange to change to the .xlsx version. OFSI will inform subscribers when this will take place, in advance of the change.
In a notification published in the Federal Register on August 26, 2019, the State Department provided additional information on restrictions on exports to Russia that were initially described by Secretary of State Mike Pompeo on August 2, 2019 when he announced the second round of targeted sanctions on Russia under the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (the “CBW Act”). Our blog post on the August 2, 2019 announcement (“Announcement”), which described sanctions measures concerning multilateral bank assistance and lending to or participation in debt offerings by the Russian sovereign, in addition to restrictions on exports to Russia described in further detail below, is available here.Read more…