On November 15, 2018, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated seventeen individuals as Specially Designated Nationals (“SDNs”) under Executive Order 13818, which implements the Global Magnitsky Human Rights Accountability Act (“Global Magnitsky Act”), in connection with the killing of journalist Jamal Khashoggi. These individuals include Saud al-Qahtani, a former top aide to the crown prince, and Mohammed al-Otaibi, the consul general of the Saudi consulate in Istanbul where Mr. Khashoggi was killed on October 2, 2018. The full list of the designated individuals can be found 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.
Under the Joint Comprehensive Plan of Action (“JCPOA”), Saturday, January 16, 2016, was “Implementation Day.” On that date, the US Government relaxed certain sanctions against Iran after the International Atomic Energy Agency confirmed that Iran had fulfilled its nuclear-related commitments under the JCPOA. These measures primarily affect parties who are not “U.S. persons” (i.e., US citizens or permanent residents (wherever located or employed), entities organized under the laws of the United States (including foreign branches), and persons…