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Alison J. Stafford Powell

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On May 1, 2023, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License No. 42 (“GL 42”) under the Venezuela Sanctions Regulations (“VSR”), three new Venezuela-related Frequently Asked Questions (“FAQs”), and also amended one Venezuela-related FAQ. These developments occurred in the context of efforts by creditors to enforce judgments against Venezuela and appear to have been in response to a request from the Special Master for the US District…

On February 24, 2023, the US Government alongside G7 leaders announced via a White House statement a new set of trade and economic measures targeting Russia and Belarus and support for Ukraine. These measures were announced to mark the one-year anniversary of the Russian invasion of Ukraine and include the following: The US Treasury Department’s Office of Foreign Assets Control (“OFAC”) (i) issued a new determination authorizing the imposition of sanctions targeting the Russian metals…

On January 17, 2023, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) amended (i) certain Russia-related General Licenses (“GLs”) and (ii) four Russia-related Frequently Asked Questions (“FAQs”). Amended General Licenses Amended GLs include the following: GL 6C, “Transactions Related to Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates, the Coronavirus Disease 2019 (COVID-19) Pandemic, or Clinical Trials,” replaces and supersedes GL 6B (see previous blog post here)…

On December 30, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued “Preliminary Guidance on Implementation of the Price Cap Policy for Petroleum Products of Russian origin” to explain how OFAC will implement a ban on the provision of services related to the maritime transportation of Russian-origin petroleum products (“Petroleum Products Guidance”). The petroleum products ban builds on a similar ban related to maritime transportation of Russian-origin crude oil that…