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.
On November 5, 2018, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) took several actions to finalize the re-imposition of sanctions against Iran in response to President Trump’s May 8, 2018 decision to cease the United States’ participation in the Joint Comprehensive Plan of Action (“JCPOA”). See our previous blog posts here regarding the President’s May 8, 2018 decision to cease the United States’ participation in the JCPOA and here regarding Executive Order (“EO”) 13846, issued on August 6, 2018, which consolidated and reissued several sanctions provisions that had been suspended or revoked while the JCPOA was in effect.
On May 1, 2018, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued General License 12B (“GL 12B”) and General License 13A (“GL 13A”), replacing and superseding in their entirety General License 12A (“GL 12A”) and General License 13 (“GL 13”), respectively. These expanded general licenses are intended to relieve some of the challenges faced by US persons, including US financial institutions, in winding down activities with and divesting interests in certain targeted Russian Specially Designated Nationals (“SDNs”). Please see our prior blog posts concerning (i) the designation of certain Russian oligarchs, government officials, and entities, and the initial issuance of General License 12 and GL 13 here and (ii) the issuance of GL 12A and General License 14 here.
On April 6, 2018, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced new sanctions measures designating as Specially Designated Nationals (“SDNs“) seven Russian oligarchs and 17 Russian government officials previously identified in a report issued pursuant to Section 241 of the Countering America’s Adversaries Through Sanctions Act (“CAATSA“; see our previous blog post on this report here) under the authority of Executive Orders 13661 and 13662, pertaining to destabilizing activities by Russia in Ukraine. OFAC also designated 12 entities owned or controlled by those newly designated oligarchs and, under the separate authority of Executive Order 13582, pertaining to support for the Government of Syria, a Russian weapons-trading company and related bank. A complete list of the designated individuals and entities is available here.