Author

Alexandre (Alex) Lamy

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In response to the Venezuelan military’s violent repression of the Venezuelan people, the U.S. Commerce Department’s Bureau of Industry and Security (“BIS”) is issuing a final rule to impose license requirements on the export, reexport, or transfer (in-country) of certain items to or within Venezuela when intended for a “military end use” or “military end user.” The final rule amends Section 744.21 of the Export Administration Regulations (“EAR”) to add a licensing requirement for Venezuela that…

On October 6, 2014, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued General License No. 3 under Executive Order 13662 of March 20, 2014.  General License No. 3 authorizes all transactions with DenizBank S.A., which are otherwise prohibited under Directive 1 of Executive Order 13662.  DenizBank is a private Turkish bank that is owned by Sberbank, a Russian bank that was sanctioned under Directive 1 on September 12, 2014.  As such, U.S. Persons are…