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Rob O'Brien (US)

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On October 9, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) added the entire International Criminal Court (“ICC”) to the Specially Designated Nationals and Blocked Persons List (“SDN List”) pursuant to Executive Order 14203 (“EO 14203”) and issued four general licenses authorizing specified transactions involving the court. Designation of the ICC Under EO 14203 OFAC has designated the ICC under section 1(a)(ii)(A) of EO 14203. The ICC designation follows OFAC’s…

On August 24, 2026, the US Department of State rescinded Syria’s designation as a State Sponsor of Terrorism (“SST”) and revoked the designation of al-Nusrah Front, also known as Hay’at Tahrir al-Sham (“HTS”), as a Specially Designated Global Terrorist (“SDGT”). Concurrently, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) removed HTS from the Specially Designated Nationals and Blocked Persons List (“SDN List”), revoked Syria General License 25 (“GL 25”), and updated…

On July 10, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License No. 2 (“GL 2”) under the Democratic Republic of the Congo Sanctions Regulations (the “DRCSR”) as the eastern Democratic Republic of the Congo (“DRC”) continues to face significant humanitarian challenges, including an Ebola outbreak in the region. GL 2 goes beyond the existing general license found in section 547.513 of the DRCSR, which is limited to…

On June 18, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued three Venezuela-related general licenses and amended FAQ 595. The most notable development is new General License 59 (“GL 59”), which authorizes certain aircraft safety-related activities for Venezuelan Specially Designated National airline, Conviasa. OFAC also reissued its telecommunications and mail authorization as General License 24A (“GL 24A”), again delayed the effectiveness of the PdVSA 2020 bond authorization through General…