On October 17, 2019, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) re-issued and amended as General License No. 13D (“GL 13D”) to continue the validity period for transactions concerning Nynas AB and its affiliates (“Nynas”), as further described below. In addition, on October 21, 2019, OFAC re-issued as General License No. 8D (“GL 8D”) to continue the validity period certain maintenance activities involving Petróleos de Venezuela S.A. (“PdVSA”) where certain entities are involved, as further described below. Finally, on October 24, 2019, OFAC re-issued and amended as General License No. 5A (“GL 5A”) to prohibit dealings or payments for three months related to a specific PdVSA bond. Our blog post regarding previous amendments to these GLs is available here.
On September 30, 2019, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) amended two Venezuela-related general licenses (“GLs”), re-issued as General License 3G (“GL 3G”) and General License 9F (“GL 9F”), to extend the authorization for dealings in certain bonds and other securities, as further outlined below. Our blog post regarding previous amendments to these GLs is available here.
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”).