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US Sanctions

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On 19 March 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) sanctioned five companies based in the United Arab Emirates (“UAE”), pursuant to Executive Order 13846 (“EO 13846”), for their alleged involvement in purchasing hundreds of thousands of metric tons of petroleum products from the National Iranian Oil Company (“NIOC”) for delivery to the UAE. The following UAE-based companies were added to the US Specially Designated Nationals and Blocked Persons List (“SDN List”):…

On October 17, 2019, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) re-issued and amended as General License No. 13D (“GL 13D”) to continue the validity period for transactions concerning Nynas AB and its affiliates (“Nynas”), as further described below.  In addition, on October 21, 2019, OFAC re-issued as General License No. 8D (“GL 8D”) to continue the validity period certain maintenance activities involving Petróleos de Venezuela S.A. (“PdVSA”) where certain entities are involved, as further described below.  Finally, on October 24, 2019, OFAC re-issued and amended as General License No. 5A (“GL 5A”) to prohibit dealings or payments for three months related to a specific PdVSA bond.  Our blog post regarding previous amendments to these GLs is available here.

On October 10, 2019, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) designated Ajay Gupta, Atul Gupta, Rajesh Gupta, and Salim Essa of South Africa (“the Guptas”) as Specially Designated Nationals (“SDNs”). The Guptas and their business associate, Essa, were designated in connection with their involvement in corruption under Executive Order 13818 (“EO 13818”), which implements and expands upon the sanctions authorities set out in the Global Magnitsky Human Rights Accountability Act. The designation of the Guptas and Essa as SDNs represents one of the most high-profile applications of the corruption-related sanctions provision of EO 13818 to date.

OFAC stated that the Guptas and Essa were members of a significant corruption network that leveraged overpayments on government contracts, bribery, and other corrupt acts to influence actions taken by the government of South Africa, in particular by facilitating their capture of government contracts and misappropriation of state assets. As a result of their designation as SDNs, all four individuals’ property and the property of any entities that are owned 50 percent or more by them, which are in the United States or in the possession or control of a US person, are now blocked.

On 14 October, the United States and European Union each adopted sanctions measures targeting Turkey, in response to Turkey’s military offensive in northern Syria.  Subject to certain exceptions discussed further below, the US measures under a new Syria-related Executive Order (“New Syria EO“) took effect immediately and authorize sanctions targeting parties engaging in certain Syria-related activities, the Government of Turkey and Turkish Government officials, and certain sectors of the Turkish economy.

The EU measures are expected to come into effect shortly.