On September 9, 2019, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued a new Venezuela-related general license (General License 34) to authorize transactions involving certain Government of Venezuela-related individuals that would otherwise be prohibited by Executive Order (“EO”) 13884.
In a notification published in the Federal Register on August 26, 2019, the State Department provided additional information on restrictions on exports to Russia that were initially described by Secretary of State Mike Pompeo on August 2, 2019 when he announced the second round of targeted sanctions on Russia under the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (the “CBW Act”). Our blog post on the August 2, 2019 announcement (“Announcement”), which described sanctions measures concerning multilateral bank assistance and lending to or participation in debt offerings by the Russian sovereign, in addition to restrictions on exports to Russia described in further detail below, is available here.
On June 6, 2019, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) amended three Venezuela-related general licenses (re-issued as General License No. 7B, General License No. 8A, and General License 13A) to clarify that these authorizations do not authorize US Persons to engage in transactions or dealings related to the exportation or reexportation of diluents, directly or indirectly, to Venezuela. Such general licenses (“GLs”) were originally issued concurrent with the designation of Petróleos de Venezuela SA (“PdVSA”) as a Specially Designated National (“SDN”) on January 28, 2019, under Executive Order 13850. Our original blog post regarding the designation of PdVSA is available here.
On Tuesday June 4, 2019, the Trump Administration announced additional changes to its Cuba policy, further restricting group people-to-people educational travel and limiting the types of aircraft and vessels authorized to travel to Cuba on temporary sojourn. Tuesday’s actions are intended to prevent travel from the United States to Cuba from enriching the Cuban military, intelligence, and security services. These changes, which took effect on June 5, 2019, are a further step toward implementation of the National Security Presidential Memorandum of June 16, 2017 “Strengthening the Policy of the United States Toward Cuba” and the Administration’s intent to restrict non-family travel to Cuba as announced by the President on April 17, 2019. Please see our blog posts covering these prior developments here and here.