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Kerry B. Contini

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On May 5, 2023, the US Department of the Treasury’s Office of Foreign Assets Controls (“OFAC”) reissued Russia-related General License 8G, “Authorizing Transactions Related to Energy.” The scope of the General License did not change since the previous reissuance; however, transactions “related to energy” with the list of entities listed in the General License are now authorized through 12:01 a.m. eastern time, November 1, 2023 (instead of expiring on May 16, 2023). General License 8D authorizes transactions “related…

On May 2, 2023, for the second time this year, the US and Turkish governments took joint action in imposing sanctions. Specifically, the United States and Türkiye imposed sanctions against two individuals determined to be financial facilitators of Syria-based terrorist groups Hay’at Tahrir al-Sham (“HTS”) and Katibat al-Tawhid wal-Jihad (“KTJ”), both of which are sanctioned by the United States and the United Nations. This follows a prior joint action in January targeting parties associated with…

Over the past eight weeks, following the announcement of the G7’s Sanctions Enforcement Coordination Mechanism, we have journeyed to our offices in each of the G7 members to ask our local sanctions experts to weigh in on what companies should know about sanctions enforcement in their jurisdiction — and what companies should be doing today to prepare — in light of the increase in sanctions enforcement, which we are already seeing on the ground. For…

On March 24, 2023, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued a final rule amending and reissuing the Belarus Sanctions Regulations, 31 CFR part 548 (the “Regulations”), to implement Executive Order (“EO”) 14038, including Directive 1 issued pursuant to EO 14038. The final rule is effective as of March 27, 2023. OFAC had previously sanctioned certain Belarussian parties as a result of Belarus’ support for and facilitation of Russia’s invasion of…