Meghan Hamilton


In a notification published in the Federal Register on August 26, 2019, the State Department provided additional information on restrictions on exports to Russia that were initially described by Secretary of State Mike Pompeo on August 2, 2019 when he announced the second round of targeted sanctions on Russia under the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (the “CBW Act”).  Our blog post on the August 2, 2019 announcement (“Announcement”), which described sanctions measures concerning multilateral bank assistance and lending to or participation in debt offerings by the Russian sovereign, in addition to restrictions on exports to Russia described in further detail below, is available here.

On July 26, 2019, the President issued an Executive Order targeting Mali entitled “Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Mali” (“Mali EO”) available here.  A White House press release on the Mali EO is available here.  The Mali EO provides authorization to the US Treasury Department, in consultation with the Department of State, to sanction individuals who are responsible for or complicit in actions that exacerbate the deteriorating situation in Mali.  The US Treasury Department’s Office of Foreign Assets Control (“OFAC”) has thus far not issued a press release related to the Mali EO or added any individuals or entities to the Specially Designated Nationals and Blocked Persons List (“SDN List”).

On June 24, 2019, the President issued Executive Order 13876, “Imposing Sanctions With Respect To Iran” (“EO 13876”), which specifically imposes sanctions on the Supreme Leader of Iran (currently, Ayatollah Khamenei) and the Supreme Leader’s Office (“SLO”), authorizes the future designation of persons appointed by, or providing support to, the SLO, and designates certain additional senior Iranian Revolutionary Guard (“IRGC”) commanders.  While a politically significant and symbolic move, by itself this latest action is unlikely to have much practical impact, except to increase the risk, yet again, of secondary sanctions for non-US parties (particularly financial institutions) that engage in transactions with the targeted parties.

On June 6, 2019, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) amended three Venezuela-related general licenses (re-issued as General License No. 7B, General License No. 8A, and General License 13A) to clarify that these authorizations do not authorize US Persons to engage in transactions or dealings related to the exportation or reexportation of diluents, directly or indirectly, to Venezuela.  Such general licenses (“GLs”) were originally issued concurrent with the designation of Petróleos de Venezuela SA (“PdVSA”) as a Specially Designated National (“SDN”) on January 28, 2019, under Executive Order 13850.  Our original blog post regarding the designation of PdVSA is available here