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 5, 2019, President Trump issued Executive Order 13884 (“Venezuela EO”) blocking all property of the Government of Venezuela (“GOV”), a significant escalation of sanctions against the regime of President Maduro. Statements issued by the White House and State Department indicate that this escalation is meant to target the Maduro regime for its continued abuses of human rights and repression. The US Department of Treasury’s Office of Foreign Assets Control (“OFAC”) concurrently issued 12 amended general licenses and 13 new general licenses, new and revised FAQs, and guidance related to the provision of humanitarian assistance and support to the Venezuelan people.
The Venezuela EO targets only the GOV and entities owned 50% or more or otherwise controlled by the GOV, and thus does not place Venezuela under a full territorial embargo. Transactions with private Venezuelan parties that can be effected without the involvement of the GOV remain permissible.
The new sanctions prohibit virtually all US Person dealings with the GOV by blocking the property and interests in property of the GOV that are in the United States, that come within the United States, or that come within the possession or control of US Persons (i.e., US companies and their branches, US banks, US citizens and permanent resident aliens, any person physically located in the United States). GOV funds, contracts or other property interests that come into the possession or control of US Persons must be blocked and reported to OFAC.
On July 23, 2019, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued an Iran-Related Civil Aviation Industry Advisory (the “Advisory”) that provides cautionary guidance to the civil aviation industry on compliance with US sanctions measures targeting Iran. The Advisory articulates the following key messages: (i) both US and non-US parties in the civil aviation industry remain at risk of US enforcement actions and economic sanctions for engaging in or supporting unauthorized transfers of aircraft or related goods, technology, or services to Iran or to designated Iranian airlines; (ii) the international civil aviation industry stakeholders – including airlines, charter operators, travel distributors and ticket agents, OEMs, suppliers, and service providers – must be on alert for certain deceptive practices used by Iran-related parties to circumvent US sanctions; and (iii) parties should be aware of certain aspects of US sanctions targeting Iran that relate specifically to the civil aviation industry.
On August 2, 2019, the US State Department announced targeted sanctions against Russia related to the March 2018 use of a “novichok” nerve agent in an attempt to assassinate UK citizen Sergei Skripal and his daughter Yulia Skripal in the United Kingdom. This was the second round of sanctions required under the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (the “CBW Act”) following the State Department’s determination on November 6, 2018 that Russia had failed to provide reliable assurances that it would not engage in future chemical weapons attacks. The US Government issued the first round of CBW Act sanctions on August 27, 2018. See our blog post on the first round of CBW Act sanctions here.