In two separate rounds of sanctions designations in the past week, the United States added more parties to the Specially Designated Nationals List (“SDN List”) maintained by the Office of Foreign Assets Control (“OFAC”) in the US Treasury Department. These designations are noteworthy given their scope and, in the case of the Iran-related designations, the fact that they included parties in China, Russia, and Türkiye. Not only does this increase the risk of encountering sanctioned…
On August 8, 2023, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued the OFAC Compliance Communique: Guidance for the Provision of Humanitarian Assistance to Syria (the “Guidance”). The Guidance responds to specific questions that OFAC received from the non-governmental organization (“NGO”) community and the general public related to the provision of humanitarian assistance to the Syrian people. In addition, OFAC amended Frequently Asked Question 937 (“FAQ 937”) related to the…
On July 10, 2023, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) reissued General License 40B, “Authorizing Certain Transactions Involving the Exportation or Reexportation of Liquefied Petroleum Gas to Venezuela” (“GL 40B”). GL 40B authorizes US persons to engage in transactions related to the exportation or reexportation, directly or indirectly, of liquefied petroleum gas (” LPG”) to Venezuela involving the Government of Venezuela (“GOV”), Petróleos de Venezuela, S.A. (” PdVSA”), any…
On June 1, 2023, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) added four (4) entities to the Specialty Designated Nationals (“SDN”) List under Executive Order 14098 (“EO 14098”) and issued four general licenses (“GLs”) authorizing certain transactions involving Sudan. For more information on EO 14098, see our previous blog post available here. We summarize the four GLs below that authorize certain activities and transactions involving SDNs designated under EO 14098.…