Janet K. Kim


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

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.

On April 17, 2019, the Trump Administration announced several decisions that mark a significant shift in US policy toward Cuba, most notably by declaring that the United States will no longer suspend Title III of the LIBERTAD Act of 1996, which is also known as the Helms-Burton Act.

On February 11, 2019, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) amended and issued two general licenses, General License 3C (“GL 3C”) and General License 9B (“GL 9B”), both related to Petróleos de Venezuela, S.A. (“PdVSA”) and entities 50% or more owned by PdVSA (“PdVSA Companies”), and revised three related FAQs, FAQs 650, 661, and 662 to provide updated guidance on GL 3C and GL 9B.