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US Sanctions

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On April 1, 2021, President Biden revoked Executive Order 13928 “Blocking Property of Certain Persons Associated with the International Criminal Court” (the “ICC EO”), which authorized the imposition of sanctions and visa restrictions on non-US ICC officials. The US Treasury Department’s Office of Foreign Assets Control concurrently removed two senior ICC officials from the Specially Designated Nationals and Blocked Persons List (“SDN List”), including Fatou Bensouda, the ICC’s chief prosecutor. The ICC EO was signed…

On January 1, 2021, the National Defense Authorization Act for Fiscal Year 2021 (the “NDAA 2021”) was enacted into law after the US Congress voted to override the President’s veto of the bill. The defense budget legislation authorizes $740.5 billion for national defense spending and sets policies on military compensation, procurement of equipment, operations, and training. In addition, similar to most National Defense Authorization Acts in recent years, the NDAA 2021 includes provisions regarding sanctions…

The Non-SDN Menu-Based Sanctions List On December 14, 2020, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published a new Non-SDN Menu-Based Sanctions List (“NS-MBS List”). The NS-MBS List is not the result of new sanctions but rather is designed as a reference tool to identify persons subject to certain non-blocking menu-based sanctions, including certain sanctions described in Section 235 of the Countering America’s Adversaries Through Sanctions Act (“CAATSA”), as implemented by…

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…