On June 5, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) published four Frequently Asked Questions (the “FAQs”) regarding Iran-related sanctions under Executive Order 13902 (“EO 13902”). EO 13902 authorizes the imposition of secondary sanctions targeting the Iranian construction, mining, manufacturing, and textile sectors and persons engaged in “significant transactions” or providing “material support” to parties designated pursuant to the order. Our blog post regarding EO 13902 is available here. The FAQs…

On February 20, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) published two new Frequently Asked Questions regarding the interim final rule of June 21, 2019 that amended the Reporting, Procedures and Penalties Regulations, 31 CFR Part 501 (the “RPPR Rule”). These FAQs hope to clarify some of the issues that arose from the interim final rule but still leaves areas of uncertainty, such as what constitutes a rejected transactions. For example,…

On September 6, 2019, the US Treasury Department Office of Foreign Assets Control (“OFAC”) announced that it is amending the Cuban Assets Control Regulations (“CACR”) to further financially isolate the Cuban government and implement President Trump’s June 2017 National Security Presidential Memorandum (“NSPM”) Strengthening the Policy of the United States Towards Cuba (the “CACR Amendment”). The CACR Amendment (1) removes the authorization for banks subject to US jurisdiction to process pass-through or “U-turn” transactions, and (2) eliminates or restricts certain types of remittances to Cuba. The CACR Amendment was published in the Federal Register on September 9, 2019, and will take effect on October 9, 2019.

OFAC also published Frequently Asked Questions and a Fact Sheet on the CACR Amendment.

On September 9, 2019, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued a new Venezuela-related general license (General License 34) to authorize transactions involving certain Government of Venezuela-related individuals that would otherwise be prohibited by Executive Order (“EO”) 13884.