On June 27, 2023, the US Departments of State, the Treasury, Labor, Commerce, and Homeland Security, and the United States Agency for International Development issued a joint advisory — the Africa Gold Advisory (“Advisory”) — that (i) highlights the opportunities and specific risks raised by the gold trade across sub-Saharan Africa and (ii) encourages industry participants to adopt and apply strengthened due diligence practices to guard against such risks. The Advisory states that it was…
On May 1, 2023, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License No. 42 (“GL 42”) under the Venezuela Sanctions Regulations (“VSR”), three new Venezuela-related Frequently Asked Questions (“FAQs”), and also amended one Venezuela-related FAQ. These developments occurred in the context of efforts by creditors to enforce judgments against Venezuela and appear to have been in response to a request from the Special Master for the US District…
On October 17, 2022, the UK HM Treasury’s Office of Financial Sanctions Implementation (“OFSI”) and the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued a joint statement (OFSI statement here, OFAC statement here) to reiterate the close working relationship between the two agencies, explaining the rationale behind increased OFSI-OFAC co-operation and how this will manifest in practice. The statement follows a technical exchange attended by OFAC and OFSI in London, which concluded on…
On August 19, 2022, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) replaced existing General License (“GL”) 38 with GL 38A and issued a new GL 50. These GLs authorize certain activities otherwise prohibited by EO 14024, which targets, among other things, specific sectors (including the financial services sector) of the Russian economy. Our prior blog post regarding EO 14024 and the financial sanctions imposed thereunder can be found here, here, here,…