On June 3, 2021, President Biden issued Executive Order 14032, “Addressing the Threat from Securities Investments that Finance Certain Companies of the People’s Republic of China” (the “CMIC EO”). This amends and replaces Executive Order 13959 (“EO 13959”) and revokes Executive Order 13974 (“EO 13974”) that restricted investments in certain “Communist Chinese Military Companies” (“CCMCs”). The main changes implemented by the CMIC EO and related public guidance are to (1) change the group of targeted…
The US Treasury Department’s Office of Foreign Assets Control (“OFAC”), the US State Department (“State”), and the US Commerce Department (“Commerce”) issued rules adjusting maximum civil monetary penalties (“CMPs”) under the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015 (“FCA”), as outlined below. (For additional years of CMPs, see our previous blog post available here.) OFAC CMP Adjustments Under OFAC’s final rule published on March 17, 2021, the adjusted penalties apply to CMPs…
On January 19, 2021, the US Commerce Department published an interim final rule to implement President Trump’s 2019 Executive Order 13873 on “Securing the Information and Communications Technology and Services Supply Chain” (“Interim Rule”). The Interim Rule was issued following the closure of the public comment period on January 10, 2021 on the proposed rules issued on November 27, 2019 (“Proposed Rules”) to implement Executive Order 13873. For more information on Executive Order 13873 and the Proposed…
On November 5, 2019, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued a new Venezuela-related general license (General License No. 35) (“GL 35”) to authorize certain administrative transactions with the Government of Venezuela (“GOV”) prohibited by Executive Order (“EO”) 13884 (“Blocking Property of the Government of Venezuela”); issued General License No. 34A (“GL 34A”), which supersedes and replaces General License No. 34, and authorizes transactions involving certain GOV-related individuals prohibited by EO 13884; and identified five current GOV officials on the Specially Designated Nationals and Blocked Persons List (“SDN List”) pursuant to EO 13884.
Then, on November 21, 2019, OFAC announced the amendment of the Venezuela Sanctions Regulations (“VSR,” 31 C.F.R. Part 591) to incorporate additional EOs; make certain clarifying changes; add a GL authorizing US Government activities; and add an interpretive provision regarding activities related to judicial processes. The VSR regulatory amendments took effect on November 22, 2019 concurrent with their publication in the Federal Register, available here.
These Venezuela sanctions developments are described in more detail below. Our previous blog posts about US sanctions targeting Venezuela are available here.