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US Executive Orders

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On January 26, 2023, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) redesignated PMC Wagner (“Wagner Group”) a Significant Transnational Criminal Organization (“STCO”) pursuant to Executive Order 13581 (“EO 13581”) as amended by Executive Order 13863 (“EO 13863”) for the Wagner Group’s activities in Ukraine, the Central African Republican (“CAR”), and Mali. Concurrently, OFAC has sanctioned the Wagner Group under Executive Order 13667 (“EO 13667”) for its activities in the CAR.…

On November 22, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published a new determination pursuant to Executive Order 14071 of April 6, 2022 (“EO 14071”) – “Determination Pursuant to Section 1 (a)(ii) of EO 14071” (“Determination”). The Determination implements the price cap policy for Russian crude oil, as anticipated based on OFAC’s September 2022 preliminary guidance related to the implementation of the policy banning the provision of services related to…

Following the G7 Finance Ministers Meeting on September 2, 2022 (see our previous blog here), on September 9, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued preliminary guidance on implementation of the policy banning the provision of services related to the maritime transportation of (i) Russian-origin crude oil and (ii) Russian-origin petroleum products (together “seaborne Russian oil”) (the “Maritime Services Policy”).  The ban under the Maritime Services Policy will…

On August 19, 2022, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) replaced existing General License (“GL”) 38 with GL 38A and issued a new GL 50. These GLs authorize certain activities otherwise prohibited by EO 14024, which targets, among other things, specific sectors (including the financial services sector) of the Russian economy. Our prior blog post regarding EO 14024 and the financial sanctions imposed thereunder can be found here, here, here,…