On October 17, 2019, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) re-issued and amended as General License No. 13D (“GL 13D”) to continue the validity period for transactions concerning Nynas AB and its affiliates (“Nynas”), as further described below. In addition, on October 21, 2019, OFAC re-issued as General License No. 8D (“GL 8D”) to continue the validity period certain maintenance activities involving Petróleos de Venezuela S.A. (“PdVSA”) where certain entities are involved, as further described below. Finally, on October 24, 2019, OFAC re-issued and amended as General License No. 5A (“GL 5A”) to prohibit dealings or payments for three months related to a specific PdVSA bond. Our blog post regarding previous amendments to these GLs is available here.Read more…
On 14 October, the United States and European Union each adopted sanctions measures targeting Turkey, in response to Turkey’s military offensive in northern Syria. Subject to certain exceptions discussed further below, the US measures under a new Syria-related Executive Order (“New Syria EO“) took effect immediately and authorize sanctions targeting parties engaging in certain Syria-related activities, the Government of Turkey and Turkish Government officials, and certain sectors of the Turkish economy.
The EU measures are expected to come into effect shortly.
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…
On July 26, 2019, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) amended General License (“GL”) 8A and reissued it as GL 8B to extend it until October 25, 2019. GL 8B now has the same expiration date as GL 13B, which was also recently extended.