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OFAC General License

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On April 3, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) re-issued and extended General License No. 13E (“GL 13E”) to continue the validity period for transactions concerning Nynas AB and its subsidiaries (“Nynas”) that otherwise would be prohibited under Executive Order 13850 or Executive Order 13884 given Nynas’s 50% indirect ownership by Petróleos de Venezuela S.A. (“PdVSA”). The authorization was extended through 12:01 am EST on May 14, 2020. In a…

On March 20, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) extended the expiration dates of two general licenses related to GAZ Group (“GAZ”), which was designated as an SDN on April 6, 2018 for being owned or controlled by Oleg Deripaska. Please see our blog post regarding this designation here, and our blog about the previous extension of these general licenses here. At the same time, OFAC expanded one of the…

On March 5, 2020, pursuant to Executive Order 13851 of November 27, 2018 and the Nicaragua Human Rights and Anticorruption Act of 2018, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) further escalated sanctions against Nicaragua by naming the Nicaraguan National Police (“NNP”) and three NNP commissioners as Specially Designated Nationals (“SDNs”), citing serious human rights abuses. OFAC previously named other officials of the NNP as SDNs in 2018 and 2019, also citing…

On February 27, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued a new Counter Terrorism and Iran-related General License No. 8 (“GL 8”) together with new frequently asked questions (“FAQs”) about the general license and the Swiss Humanitarian Trade Arrangement (“SHTA”). New GL 8 authorizes US Persons and non-US entities owned or controlled by US Persons to engage in Iran-related humanitarian transactions even if the CBI is directly or indirectly involved.…