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Callie Lefevre (US)

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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. 

US Government Will Not Reissue Sanctions Waivers for Countries Importing Iranian Oil

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On April 22, 2019, the Trump Administration announced that the US government will not reissue the  significant reduction exceptions (“SREs”) that have allowed energy companies in China, India, Italy, Greece, Japan, South Korea, Taiwan, and Turkey to purchase Iranian oil without being subject to relevant US sanctions. The current waivers will expire on May 2, 2019.

US Government to Allow Private Actions under Helms-Burton Act Against Entities on Cuba Restricted List

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On March 4, 2019, Secretary of State Pompeo announced that beginning on March 19, the suspension of the right to bring private actions in US federal court against Cuban entities handling confiscated property under Title III of the 1996 Cuban Liberty and Democratic Solidarity (LIBERTAD) Act (known as the “Helms-Burton Act”) will not apply to Cuban entities or sub-entities identified on the State Department’s List of Restricted Entities and Sub-entities Associated with Cuba (the “Cuba Restricted List,” available here). The right to sue all other Cuban entities and foreign entities under Title III has been further suspended, but only for a 45 day period through April 17, 2019.

US Government Sanctions 17 Individuals In Connection With The Killing Of Jamal Khashoggi

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On November 15, 2018, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated seventeen individuals as Specially Designated Nationals (“SDNs”) under Executive Order 13818, which implements the Global Magnitsky Human Rights Accountability Act (“Global Magnitsky Act”), in connection with the killing of journalist Jamal Khashoggi.  These individuals include Saud al-Qahtani, a former top aide to the crown prince, and Mohammed al-Otaibi, the consul general of the Saudi consulate in Istanbul where Mr. Khashoggi was killed on October 2, 2018.  The full list of the designated individuals can be found here.