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OFAC Issues Amended Venezuela-Related General License and Ukraine-Related General Licenses

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On June 26, 2019, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) amended Venezuela-related General License 13A (re-issued as General License 13B) to extend its expiration date from July 27, 2019 to October 25, 2019.  General License 13B continues to authorize transactions with Nynas AB, which is owned more than 50% by Petróleos de Venezuela SA (“PdVSA”), and any of Nynas AB’s subsidiaries.  PdVSA was designated as a Specially Designated National (“SDN”) on January 28, 2019, under Executive Order 13850.  Our original blog post regarding the designation of PdVSA is available here.  Dealings with entities owned 50% or more by PdVSA are prohibited absent OFAC authorization (i.e., a general or specific license).  Our previous blog post regarding the application of US sanctions to certain PdVSA subsidiaries is available here.

In addition, OFAC extended the expiration dates of two general licenses related to GAZ Group (“GAZ”), which was designated as an SDN on April 6, 2018 for being owned or controlled by Oleg Deripaska.  Please see our blog post regarding this designation here.  The GAZ-related general licenses were amended as follows:

  • General License 13L. OFAC extended the expiration of General License 13K (reissued as General License 13L) from July 6, 2019 to November 8, 2019.  General License 13L authorizes certain transactions ordinarily incident and necessary to divest or transfer debt, equity, or other holdings in GAZ to non-US persons.
  • General License 15F. OFAC extended the expiration date of General License 15E (reissued as General License 15F) from July 6, 2019 to November 8, 2019.  In addition, OFAC added to General License 15F a new authorization for the installation of Electronic Stability Program systems consistent with applicable automotive safety regulatory requirements in vehicles produced by GAZ or any entity it owns 50% or more.  Consistent with prior versions of this General License, General License 15F also authorizes certain activities ordinarily incident and necessary to the maintenance or wind down of operations or existing contracts involving GAZ or any other entity 50% or more owned by GAZ.

 

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Callie C. Lefevre is an associate in the Washington, DC office where she is a member of the International Practice Group. Her practice is focused on all aspects of International Trade law, particularly compliance with US export controls, trade and economic sanctions, and US foreign investment restrictions. *Admitted in New York only. Practice limited to matters and proceedings before US courts and federal agencies.

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Inessa Owens is an associate in the Washington, D.C. office and member of the Firm’s International Trade practice group. She focuses on outbound trade compliance issues, including compliance with the Export Administration Regulations, anti-boycott rules, and economic sanctions administered by the US Treasury Department’s Office of Foreign Assets Control, including those targeting Cuba, Iran, North Korea, Syria, and Russia. She has worked with clients in diverse industries that include finance, pharmaceuticals, and energy.

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Ms. Kim focuses on outbound trade compliance issues that arise under US economic sanctions, export control laws, investment restrictions, anti-boycott regulations, anti-money laundering laws and the Foreign Corrupt Practices Act. She represents and advises US and non-US companies in criminal and regulatory proceedings, internal investigations, and compliance audits relating to these areas of law. She also advises on the extraterritorial application of these laws in cross-border transactions, including mergers and acquisitions, joint venture arrangements, and other international commercial activities. Her practice includes the development and implementation of workable, risk-based internal compliance programs and procedures for companies in a wide range of industries.

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