On May 21, 2018, the President signed a new Executive Order (the “Order”) related to Venezuela entitled “Prohibiting Certain Additional Transactions with Respect to Venezuela.” According to a statement from the White House, this action is intended to “prevent the Maduro regime from … liquidating Venezuela’s critical assets.” These new US financial sanctions were imposed after Venezuela held elections this past weekend that were described as “fraudulent” in a press statement from the US State Department. Please see our prior blog posts concerning the previous Venezuela-related Executive Orders: (i) Executive Order 13827 of March 19, 2018 here, (ii) Executive Order 13808 of August 24, 2017 here, and (iii) Executive Order 13692 of March 8, 2015 here.
On March 22, 2018, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule (the “Final Rule”) adding, in relevant part, 15 South Sudanese entities to the Export Administration Regulations’ (“EAR”) Entity List — a step that increases the pressure on that country following the US Government’s imposition of an arms embargo last month. All 15 entities are subject to a license requirement for all exports, reexports, or in-country transfers of items subject to the EAR, and new license applications for these entities are subject to a presumption of denial.
On November 27, 2017, the US State Department published a notice in the Federal Register that North Korea was designated as a State Sponsor of Terrorism (“SST”) on November 17, 2017. North Korea was originally designated as an SST in 1988 in connection with the bombing of a Korean Air flight but was delisted in 2008 by President George W. Bush as part of negotiations over its nuclear program.
On September 21, 2017, President Trump issued an Executive Order (“Order”) imposing additional sanctions on North Korea. The Order is aimed at curbing North Korea’s ability to fund its nuclear and ballistic missile programs by giving the Secretary of the Treasury additional tools to target non-US persons engaging in trade with North Korea and non-US financial institutions supporting such trade.