On February 18, 2019, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), pursuant to Executive Order 13850 (“EO 13850”), designated Rosneft Trading S.A., the Swiss-incorporated, Russian-controlled oil brokerage firm, as a Specially Designated National (“SDN”) for operating in the oil sector of the Venezuelan economy. OFAC also designated the President and Chairman of Rosneft Trading S.A., Didier Casimiro, as an SDN for purporting to act for or on behalf of, directly…
On 14 October, the United States and European Union each adopted sanctions measures targeting Turkey, in response to Turkey’s military offensive in northern Syria. Subject to certain exceptions discussed further below, the US measures under a new Syria-related Executive Order (“New Syria EO“) took effect immediately and authorize sanctions targeting parties engaging in certain Syria-related activities, the Government of Turkey and Turkish Government officials, and certain sectors of the Turkish economy.
The EU measures are expected to come into effect shortly.
On October 9, 2019, the US Commerce Department’s Bureau of Industry and Security (“BIS”) added 28 Chinese entities to the Entity List because they are accused by the US Government of being associated with human rights violations and abuses against Uighurs, Kazakhs, and other members of Muslim minority groups in the Xinijiang Uighur Autonomous Region (“XUAR”). All exports, reexports, or in-country transfers of items (i.e., goods, software, technology) subject to the Export Administration Regulations (“EAR”), including EAR99 items, are now subject to a license requirement to such entities. The final rule also includes an extensive list of aliases for these entities.
On September 20, 2019, in response to recent attacks on certain Saudi Arabian oil facilities, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) took action pursuant to Executive Order 13224 against three Iranian entities: (i) the National Development Fund of Iran (“NDF”) (ii) Etemad Tejarat Pars Co., and (iii) the Central Bank of Iran (“CBI”). Executive Order 13224 authorizes the designation of parties if, among other things, they attempt to commit, or pose a significant risk of committing, acts of terrorism.