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CAATSA

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On April 10, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued a rule amending the North Korea Sanctions Regulations (“NKSR”). The NKSR amendments implement certain provisions of the North Korea Sanctions and Policy Enhancement Act of 2016 (“NKSPEA”), as amended by the Countering America’s Adversaries Through Sanctions Act (“CAATSA”), and the National Defense Authorization Act for Fiscal Year 2020 (“2020 NDAA”). Our prior blog post on NKSPEA can be found here…

Extension of General Licenses

On November 9, 2018, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) temporarily extended the expiration dates of four general licenses related to EN+ Group PLC (“EN+”), United Company RUSAL PLC (“RUSAL”), and GAZ Group (“GAZ”) from December 12, 2018 to January 7, 2019.  Please see our blog posts on the original designation of these companies and previous extensions of these general licenses here and here.  The Treasury Department press release indicates that EN+, RUSAL, and GAZ are proposing substantial corporate governance changes that could potentially result in significant changes in control and ultimately lead to these entities’ removal from the Specially Designated Nationals and Blocked Persons List (“SDN List”).

In the past week, the US Government took several significant steps related to the US sanctions against Russia.  These included imposing sanctions pursuant to Section 231 of the Countering America’s Adversaries Through Sanctions Act (“CAATSA”) for the first time and expanding the list of persons and entities identified as being part of the Russian defense or intelligence sectors under CAATSA Section 231.  The US Government also clarified the scope of a sanctions waiver impacting foreign subsidiaries in Russia under the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (the “CBW Act”).  Finally, the US Government extended the expiration dates for several general licenses related to United Company RUSAL PLC (“RUSAL”) and EN+ Group PLC (“EN+ Group”).

On May 22, 2018, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued General License 15 (“GL 15”) and General License 12C (“GL 12C”), replacing and superseding General License 12B (“GL 12B”).  Please see our prior blog posts concerning (i) the designation of certain Russian parties here and (ii) the issuance of GL 12B here.