On April 17, 2019, the Trump Administration announced several decisions that mark a significant shift in US policy toward Cuba, most notably by declaring that the United States will no longer suspend Title III of the LIBERTAD Act of 1996, which is also known as the Helms-Burton Act.
On April 17, 2019, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) continued its escalation of sanctions against Venezuela and Nicaragua through the designation of additional parties as Specially Designated Nationals (“SDNs”). OFAC issued two Venezuelan general licenses (“GLs”), amended certain Venezuelan GLs, and issued one FAQ, as further described below. A summary of OFAC’s measures is available here, and a related press release issued by the White House is available here.
On April 8, 2019, the Trump administration escalated pressure on Iran by announcing its plan to designate the Islamic Revolutionary Guard Corps (“IRGC”) as a Foreign Terrorist Organization (“FTO”) under Section 219 of the Immigration and Nationality Act. The designation marks the first time the United States has branded a foreign government military entity a terrorist group. In retaliation, Iran designated US forces in the Middle East as a terrorist group.
The US Treasury Department’s Office of Foreign Assets Control (“OFAC”) continues to escalate the use of sanctions against the Maduro regime as well as entities that support the Maduro regime through the designation of high-profile parties as Specially Designated Nationals (“SDNs”). These designations increase the compliance risks for both US and non-US parties attempting to do business with Venezuela. Companies should watch out for additional designations under the Venezuelan sanctions, including possible designations of companies in the financial sector, gold sector, or other key sectors of the Venezuelan economy.