On March 19, 2018, the President issued a new Executive Order related to Venezuela entitled “Taking Additional Steps to Address the Situation in Venezuela” (“Venezuela EO”) available here. The Venezuela EO is the first Executive Order that specifically targets the use of cryptocurrency. Please see our prior blog posts concerning the previous Venezuela-related Executive Orders: (i) Executive Order 13808 of August 24, 2017 here and (ii) Executive Order 13692 of March 8, 2015 here.
As part of its continuing efforts to isolate North Korea from the world economy, on February 23, 2018, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced new sanctions measures targeting North Korea’s shipping industry and issued an advisory document entitled “North Korea Sanctions Advisory,” which highlights sanctions risks in the global shipping industry.
On December 20, 2017, President Trump signed Executive Order (“Order”) 13818 titled “Blocking the Property of Persons Involved in Serious Human Rights Abuses or Corruption”. The Order implements the Global Magnitsky Human Rights Accountability Act (“Global Magnitsky Act”), which was signed into law on December 23, 2016 and which targets human rights abusers and corrupt actors globally. This is to be contrasted with the Sergei Magnitsky Rule of Law Accountability Act of 2012 (“Magnitsky Act”) targeting human rights abusers in Russia, with respect to which the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) published regulations on December 21, 2017. In addition, OFAC designated a number of individuals and entities as Specially Designated Nationals (“SDNs”) under the Magnitsky Act on December 20, 2017 and under the Global Magnitsky Act on December 21, 2017.
On October 31, 2017, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) amended and reissued Directive 4 of the Ukraine/Russia-related sectoral sanctions (“Directive 4”), which targets the Russian energy sector, and updated its guidance regarding the implementation of Ukraine/Russia-related sanctions. OFAC’s amendment and reissuance of Directive 4 was expected pursuant to Section 223(d) of Title II of the Countering America’s Adversaries Through Sanctions Act (“CAATSA” see our previous blog post on CAATSA here). Also under CAATSA, Directive 1 and Directive 2 were amended and reissued on September 29, 2017 (see our previous blog post here). OFAC originally published Directive 4 in September of 2014, pursuant to Executive Order 13662. In conjunction with OFAC’s guidance, the US Department of State (“State Department”) also published guidance regarding CAATSA Sections 225 and 232.