On May 1, 2018, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued General License 12B (“GL 12B”) and General License 13A (“GL 13A”), replacing and superseding in their entirety General License 12A (“GL 12A”) and General License 13 (“GL 13”), respectively. These expanded general licenses are intended to relieve some of the challenges faced by US persons, including US financial institutions, in winding down activities with and divesting interests in certain targeted Russian Specially Designated Nationals (“SDNs”). Please see our prior blog posts concerning (i) the designation of certain Russian oligarchs, government officials, and entities, and the initial issuance of General License 12 and GL 13 here and (ii) the issuance of GL 12A and General License 14 here.
On March 19, 2018, the President issued a new Executive Order related to Venezuela entitled “Taking Additional Steps to Address the Situation in Venezuela” (“Venezuela EO”) available here. The Venezuela EO is the first Executive Order that specifically targets the use of cryptocurrency. Please see our prior blog posts concerning the previous Venezuela-related Executive Orders: (i) Executive Order 13808 of August 24, 2017 here and (ii) Executive Order 13692 of March 8, 2015 here.
On July 11, 2017, President Trump signed an Executive Order allowing additional time to consider actions by the Government of Sudan before lifting US sanctions on Sudan (“July Executive Order”).
On April 18, 2017, the US Department of State notified the US Congress that Iran has been complying with the conditions of the Joint Comprehensive Plan of Action (“JCPOA”). The US Department of State is required to notify the US Congress every 90 days on Iran’s compliance with the JCPOA, and the April 18, 2017, notification was the first such notification under the Trump Administration.