On August 24, 2017, President Trump signed an Executive Order (“Order”) imposing additional sanctions on Venezuela. The Order states that these sanctions, which primarily target the Government of Venezuela and the Venezuelan oil industry, are in response to the deepening political and humanitarian crisis in Venezuela. The Order adds to a growing list of restrictions that apply to Venezuela, which is already subject to an arms embargo and licensing requirements on exports and reexports of specific categories of goods, software, and technology to military end-users or for military end-uses in Venezuela. The Order also follows the designation as Specially Designated Nationals of various Venezuelan government officials (including President Nicolas Maduro) pursuant to Executive Order 13692 of March 8, 2015 (see prior blog post here regarding this order).
On June 29, 2017, the US Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued for public inspection a notice of proposed rulemaking (the “Proposed Rule”) that would restrict a Chinese commercial bank’s access to the US financial system based on a finding that the bank was involved in money laundering activities involving North Korea. This action coincided with designations by the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) of one entity and two individuals with alleged ties to North Korea.
The US Treasury Department’s Office of Foreign Assets Control (“OFAC”), the US Department of State’s Directorate of Defense Trade Control (“DDTC”), and the US Department of Commerce’s Bureau of Industry and Security (“BIS”) have announced increases in the maximum civil monetary penalties (“CMPs”) under the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015 (“2015 Act”). This statute requires the agencies to make such adjustments annually by January 15 of each year. These newly adjusted CMPs may be imposed for violations of OFAC sanctions regulations, the International Traffic in Arms Regulations, and the Export Administration Regulations (“EAR”). Although these are the first annual adjustments made under the 2015 Act, they follow initial “catch-up” adjustments that went into effect on August 1, 2016 and were previously described here.
On January 4, 2017, the US Commerce Department’s Bureau of Industry and Security (“BIS”) added five Russian parties to its Entity List. The move follows the issuance of amended Executive Order 13694 (“Cyber EO2”) on December 29, 2016 and the subsequent designation of five Russian entities and four individuals on the US Treasury Department’s Office of Foreign Assets Control’s (“OFAC”) Specially Designated Nationals and Blocked Persons List (“SDN List”) (see prior blog post here).