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 26, 2023, the US Departments of Treasury, Commerce, and Justice published a Tri-Seal Compliance Note on the voluntary self-disclosure (“VSD”) of potential violations of US sanctions, export controls, and other national security laws (the “VSD Note”). This publication is the second Tri-Seal Compliance Note issued by the agencies and continues the enforcement focus on the sanctions and export control measures targeting Russia in particular and national security concerns more generally. The first Tri-Seal…
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 27, 2023, the US Departments of State, the Treasury, Labor, Commerce, and Homeland Security, and the United States Agency for International Development issued a joint advisory — the Africa Gold Advisory (“Advisory”) — that (i) highlights the opportunities and specific risks raised by the gold trade across sub-Saharan Africa and (ii) encourages industry participants to adopt and apply strengthened due diligence practices to guard against such risks. The Advisory states that it was…