On September 18, 2023, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) established a new humanitarian channel (“HC”) in Qatar to facilitate the provision of humanitarian assistance to the Iranian people. The HC is similar to humanitarian channels established under previous administrations and is designed to help the Iranian people gain access to food, agricultural goods, medicine, and medical devices, while ensuring that funds are not misused and is intended…
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 14, 2023, the US State Department, the Labor Department, and the Commerce Department issued a business advisory (“Business Advisory”) highlighting key risks for companies operating in South Sudan. While it does not impose new legal obligations on companies, the Business Advisory highlights the fact that list-based sanctions remain in force targeting certain South Sudanese persons including designations under the US Treasury Department’s Office of Foreign Assets Control’s Specially Designated Nationals and Blocked Persons List, and…
On August 23, 2023, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued the first Determination Pursuant to Section 1(a)(i) of Executive Order (“EO”) 14014 (the “Determination”), which extends the application of section 1(a)(i) of EO 14014 to the jet fuel sector of the Burmese economy. On the same day, OFAC also published two related Frequently Asked Questions (“FAQs”): FAQ 1132 and FAQ 1133. Our blog post on the issuance of EO 14014…