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Nicholas Coward (US)

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Commerce Proposes Rules re Securing the Information and Communications Technology and Services Supply Chain; Comments Due on or Before December 27

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On November 26, 2019, the US Department of Commerce (“Commerce”) issued a highly anticipated proposed rule with proposed regulations (“Proposed Regulations”) to implement Executive Order 13873, “Securing the Information and Communications Technology and Services Supply Chain” (“Executive Order 13873“).

Executive Order 13873 gives the Secretary of Commerce (“Secretary”) sweeping, unprecedented authority to prevent or modify transactions involving information and communications technology and services (“ICTS”) originating in countries designated as “foreign adversaries” which pose an undue risk to critical infrastructure or the digital economy in the United States, or an unacceptable risk to US national security or the safety of United States persons. All industries are potentially affected by the Proposed Regulations, whether directly or indirectly, which allow for case-by-case reviews of transactions at the Secretary’s discretion. Any transaction that is ongoing as of, or was initiated on or after, May 15, 2019, can be reviewed and there is no mechanism by which a company may seek to clear transactions in advance.

A summary of the background and the Proposed Regulations is provided below:

US Government Amends Venezuela-Related General License to Allow Certain Companies to Continue Operations in Venezuela Involving PdVSA until October 25, 2019

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On July 26, 2019, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) amended General License (“GL”) 8A and reissued it as GL 8B to extend it until October 25, 2019. GL 8B now has the same expiration date as GL 13B, which was also recently extended.

OFAC Designates Central Bank of Venezuela and Other Venezuelan and Nicaraguan Parties, Issues and Amends Venezuelan General Licenses, and Issues FAQ

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On April 17, 2019, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) continued its escalation of sanctions against Venezuela and Nicaragua through the designation of additional parties as Specially Designated Nationals (“SDNs”).  OFAC issued two Venezuelan general licenses (“GLs”), amended certain Venezuelan GLs, and issued one FAQ, as further described below.  A summary of OFAC’s measures is available here, and a related press release issued by the White House is available here.

Application of US Sanctions Targeting Venezuela to PdVSA Subsidiaries

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On January 28, 2019, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) designated Petróleos de Venezuela, S.A. (“PdVSA”) as a Specially Designated National (“SDN”) under Executive Order 13850 of November 1, 2018.  As a result, US Persons are prohibited from dealing with PdVSA as of January 28, unless authorized by OFAC.  (For these purposes, US Persons are entities organized under US laws and their non-US branches; individuals and entities physically located in the United States; US citizens and permanent resident aliens (“Green Card” holders) wherever located or employed.)

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