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Meghan Hamilton

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On February 18, 2016, the President signed into law the “North Korea Sanctions and Policy Enhancement Act of 2016” (H.R. 757) (the “NKSPEA”), which passed Congress by an overwhelming majority in the U.S. House of Representatives and a unanimous vote in the U.S. Senate. NKSPEA sets out several new sanctions against North Korea, including the following: 1. Blocking of the Government of North Korea: Section 104(c) of NKSPEA requires imposition of a “blocking” order (i.e., asset freeze)…

On October 29, 2015, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued Belarus-related General License No. 2, authorizing transactions otherwise prohibited by, and involving Belarusian entities blocked pursuant to, Executive Order 13405. The general license is effective only from October 30, 2015 through April 30, 2016, unless extended or revoked. General License No. 2 applies to all Belarusian entities currently identified as specially designated nationals (“SDNs”) pursuant to Executive Order 13405, and any entities…