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,…
On April 28, 2020, the Department of Commerce’s Bureau of Industry and Security (“BIS”) published two new final rules and a proposed rule in the Federal Register amending the Export Administration Regulations (“EAR”) to tighten restrictions on exports of technology to China, Russia, and Venezuela. According to Commerce Secretary Wilbur Ross, these actions are intended to combat efforts by entities in China, Russia, and Venezuela to use certain US technologies obtained through civilian supply chains…