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Sanctions Targeting Venezuela

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On December 23, 2020, the US Commerce Department’s Bureau of Industry and Security (“BIS”) issued a final rule amending the Export Administration Regulations (“EAR”) by adding a new “Military End User List” (“MEU List”) as supplement no. 7 to part 744 of the EAR. The final rule adds 102 entities to the MEU List, which will consist of Chinese, Russian, and Venezuelan entities that the US Government has determined are “military end users” for purposes…

On November 17, 2020, the US Treasury Department’s Office of Foreign Asset Control (“OFAC”) amended General License (“GL”) 8F and re-issued it as General License 8G.  GL 8G extends the validity period of certain limited maintenance and wind-down transactions and activities involving Petróleos de Venezuela S.A. (“PdVSA”) until June 3, 2021.   Our blog posts describing previous amendments to the general license are available here, here, here, and here. Specifically, GL 8G extends the validity period of the authorization…

On October 29, 2020, the US Commerce Department’s Bureau of Industry and Security (“BIS”) issued a final rule (the “final rule”) amending the license review policy under the Export Administration Regulations (“EAR”) for items controlled for national security (“NS”) reasons when destined to China, Russia, or Venezuela. The amendments add Venezuela to the list of countries to which the policy applies and modify the policy to replace the reference to military capabilities with a new,…

On May 12, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced the lifting of US sanctions on Nynas AB (“Nynas”) and the related revocation of General License No. 13E (“Authorizing Certain Activities Involving Nynas AB”) (“GL 13E”). We blogged about last month’s extension of GL 13E here. Nynas and its subsidiaries were previously subject to US sanctions because Nynas was indirectly owned and controlled by Petróleos de Venezuela SA (“PdVSA”) and,…