On February 6, 2025, the US State Department reversed the Biden Administration’s revocation of President Trump’s National Security Presidential Memorandum 5 of June 16, 2017 and recreated the Cuba Restricted List (“CRL” or “List”), which identifies entities and subentities that are controlled by, or acting on behalf of, the Cuban military, intelligence, or security services or personnel. The US State Department also added a Cuban remittance provider to the CRL, effective March 10, 2025. For…
On January 10, 2025, in a multilateral sanctions action, the US, Canada, EU, and UK sanctioned various Venezuelan individuals linked to the Venezuelan government and prominent state-owned entities. US Sanctions The US Treasury Department’s Office of Foreign Assets Control (“OFAC”) designated eight Venezuelan individuals as Specially Designated Nationals pursuant to Executive Order 13692, including the president of the Specially Designated National state-owned petroleum company, Petroleos de Venezuela, S.A., (PdVSA), the Venezuelan Ministry of Transportation and…
On 10 January 2025, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and the UK’s Office of Financial Sanctions Implementation (“OFSI”) announced the designations of two major Russian oil companies, PJSC Surgutneftegas and Gazprom Neft. The US and the UK have introduced new general licenses to permit limited activity relating to these entities, detailed further below. OFAC also designated numerous energy sector parties and issued a new Russia-related petroleum services prohibition.…
On December 2, 2024, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued long anticipated and extensive new controls to impair China’s indigenous production of advanced semiconductors and other items that can be used in advanced weapon systems, AI, and advanced computing in support of China’s military-civil fusion program. The new rules have a particular focus on the tools used in semiconductor manufacturing and on certain high bandwidth memory (“HBM”), and this…