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Inessa Owens

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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 Issues 90-Day Temporary General License Authorizing Certain Transactions with Huawei and its Affiliates

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Effective May 20, 2019, the US Commerce Department’s Bureau of Industry and Security (“BIS”) issued a final rule creating a 90-day Temporary General License (“TGL”) authorizing certain transactions involving the export, reexport, and transfer of items subject to the Export Administration Regulations (“EAR”) to Chinese-headquartered Huawei Technologies Co. Ltd. (“Huawei”) and its sixty-eight non-US affiliates, which were added to the BIS Entity List effective May 16, 2019 (the “Entity List designation”). The TGL will be effective through August 19, 2019.  Please see our prior blog post here for more information on the Entity List designation.

OFAC Publishes “A Framework for Compliance Commitments”

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On May 2, 2019, the US Office of Foreign Assets Control (“OFAC”) published A Framework for OFAC Compliance Commitments (the “Framework”).  This long-awaited document sets out OFAC’s expectations for effective sanctions compliance programs (“SCPs”).  While the broad elements of the Framework should be familiar to seasoned compliance practitioners, the details highlight the specific significance that OFAC attaches to SCPs in resolving enforcement actions.  Indeed, we are already seeing OFAC settlements conditioned on compliance enhancements reflected in the Framework.

Trump Administration Plans to Designate Iran’s Islamic Revolutionary Guard Corps as a Foreign Terrorist Organization

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On April 8, 2019, the Trump administration escalated pressure on Iran by announcing its plan to designate the Islamic Revolutionary Guard Corps (“IRGC”) as a Foreign Terrorist Organization (“FTO”) under Section 219 of the Immigration and Nationality Act. The designation marks the first time the United States has branded a foreign government military entity a terrorist group. In retaliation, Iran designated US forces in the Middle East as a terrorist group.

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