Olivia Colvill


The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and the US Commerce Department’s Bureau of Industry and Security (“BIS”) announced final rules effective November 9, 2017, implementing the National Security Presidential Memorandum (“NSPM“) “Strengthening the Policy of the United States Toward Cuba,” signed by President Trump on June 16, 2017.  These final rules are available here and here.  Concurrent with the announcement of the final rules, OFAC and BIS each issued new and updated Cuba FAQs (available here and here).  OFAC also issued a Fact Sheet explaining the amendments resulting from its Final Rule.

On August 24, 2017, President Trump signed an Executive Order (“Order”) imposing additional sanctions on Venezuela. The Order states that these sanctions, which primarily target the Government of Venezuela and the Venezuelan oil industry, are in response to the deepening political and humanitarian crisis in Venezuela. The Order adds to a growing list of restrictions that apply to Venezuela, which is already subject to an arms embargo and licensing requirements on exports and reexports of specific categories of goods, software, and technology to military end-users or for military end-uses in Venezuela. The Order also follows the designation as Specially Designated Nationals of various Venezuelan government officials (including President Nicolas Maduro) pursuant to Executive Order 13692 of March 8, 2015 (see prior blog post here regarding this order).

On June 20, 2017, the US Office of Foreign Assets Control (“OFAC”) announced that it had added 38 individuals and entities to the Specially Designated Nationals and Blocked Persons List (“SDN List”) and 20 entities to the Sectoral Sanctions Identification List (“SSI List”) under US sanctions targeting Russia and Crimea.  On June 21, 2017, the US Bureau of Industry and Security (“BIS”) also announced that it would add some of these SDN entities to the Entity List.

The Department of Commerce’s Bureau of Industry and Security (“BIS”) announced a final rule, effective today, March 29, 2017, to amend the Export Administration Regulations (“EAR”) to remove Zhongxing Telecommunications Equipment Corporation (“ZTE”) and its subsidiary, ZTE Kangxun Telecommunications Ltd. (“ZTE Kangxun”), from the Entity List.  ZTE and ZTE Kangxun were originally placed on BIS’s Entity List on March 8, 2016.