On July 26, 2019, the President issued an Executive Order targeting Mali entitled “Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Mali” (“Mali EO”) available here. A White House press release on the Mali EO is available here. The Mali EO provides authorization to the US Treasury Department, in consultation with the Department of State, to sanction individuals who are responsible for or complicit in actions that exacerbate the deteriorating situation in Mali. The US Treasury Department’s Office of Foreign Assets Control (“OFAC”) has thus far not issued a press release related to the Mali EO or added any individuals or entities to the Specially Designated Nationals and Blocked Persons List (“SDN List”).
The US Treasury Department’s Office of Foreign Assets Control (“OFAC”), the US State Department (“State”), and the US Commerce Department (“Commerce”) issued rules adjusting maximum civil monetary penalties (“CMPs”) under the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015 (“FCA”).
On May 8, 2019, President Trump issued Executive Order 13871 (the “Iran Metals EO”) imposing sanctions on the iron, steel, aluminum, and cooper sectors of Iran subject to a 90-day wind-down period that will expire on August 6, 2019. Although the sale, supply or transfer to/from Iran of steel and aluminum is already targeted by Section 1245 of the Iran Freedom and Counter-Proliferation Act of 2012, the Iran Metals EO expands upon those sanctions and further targets the Iranian iron and copper sectors.
On March 14, 2019, OFAC reissued General License 7 (“GL 7”) as General License 7A (“GL 7A”) to extend the general license’s authorization for certain activities involving PDV Holding, Inc. (“PDVH”) and CITGO Holding, Inc. (“CITGO”). While the original GL 7(a) was set to expire on July 27, 2019, GL 7A(a) automatically renews on the first day of each month, and is valid for a period of 18 months from the last renewal date. GL 7A(a) authorizes certain transactions with PDVH, CITGO, and their subsidiaries that would otherwise be prohibited as a result of the designation of their parent, Petroleos de Venezuela, S.A. (“PdVSA”), on January 28, 2019 under Executive Order 13850. We note that the separate petroleum-related provision that appears in GL 7(b) has not changed, and still expires on April 28, 2019. GL 7A(b) continues to authorize PDVH, CITGO, and their subsidiaries to engage in transactions ordinarily incident and necessary to the purchase and importation of petroleum and petroleum products from PdVSA (and any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest). Our prior blog posts on the scope of GL 7 are here and here.