Edward E. Dyson


On July 6, 2016, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced that it had added 16 new North Korean parties, including 11 individuals and 5 entities, to the Specially Designated Nationals and Blocked Persons List (“SDN List”).  The Treasury Department has issued a press release related to the designations.  The new SDNs include North Korea leader Kim Jong Un, other top officials of the North Korean regime, and certain North Korean government entities.  The parties were designated as Specially Designated Nationals (“SDNs”) pursuant to Executive Orders 13722 and 13687 for their ties to human rights abuses in North Korea. 

On June 8, 2016, the US Treasury Department’s Office of Foreign Assets Control (OFAC) updated its list of Frequently Asked Questions (FAQs) Relating to the Lifting of Certain US Sanctions Under the Joint Comprehensive Plan of Action (JCPOA).  These updates build on OFAC’s existing JCPOA FAQs and further clarify the scope of sanctions relief that the US Government instituted on Implementation Day (January 16, 2016).  For more information on Implementation Day, please see our blog post here.  In particular, OFAC offered additional guidance related to the parameters for foreign entities that are owned or controlled by US persons and the lifting of certain financial and banking sanctions.  This is the first time OFAC has provided public guidance about some of the issues described below (e.g., recusal policies, management issues for US parent companies), and such guidance is relevant in contexts beyond US sanctions targeting Iran.

On March 15, 2016, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) and the US Commerce Department’s Bureau of Industry and Security (“BIS”) announced further amendments (the “Amendments”) to the Cuban Assets Control Regulations (“CACR”) and the Export Administration Regulations (“EAR”), in a continuing effort to implement elements of the policy announced by President Obama on December 17, 2014 and to chip away at the decades-old embargo. The Amendments have been issued in anticipation of President Obama’s inaugural visit to Cuba next week and follow several earlier rounds of relaxation, including those made on January 15, 2015, September 18, 2015, and January 26, 2016. The Amendments went into effect on March 16, 2016.

On December 7, 2015, the Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued a six-month general license (“General License 20”) to allow certain transactions otherwise prohibited by the Burmese Sanctions Regulations (“BSR”) that are incidental to permissible exports to or from Burma. OFAC’s statement on the issuance of General License 20, which was issued to support US and Burmese exporters and to facilitate trade with Burma, is available here. General License 20 authorizes all transactions until…