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US Imposed Sanctions

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On September 21, 2017, President Trump issued an Executive Order (“Order”) imposing additional sanctions on North Korea.  The Order is aimed at curbing North Korea’s ability to fund its nuclear and ballistic missile programs by giving the Secretary of the Treasury additional tools to target non-US persons engaging in trade with North Korea and non-US financial institutions supporting such trade.

On August 24, 2017, President Trump signed an Executive Order (“Order”) imposing additional sanctions on Venezuela. The Order states that these sanctions, which primarily target the Government of Venezuela and the Venezuelan oil industry, are in response to the deepening political and humanitarian crisis in Venezuela. The Order adds to a growing list of restrictions that apply to Venezuela, which is already subject to an arms embargo and licensing requirements on exports and reexports of specific categories of goods, software, and technology to military end-users or for military end-uses in Venezuela. The Order also follows the designation as Specially Designated Nationals of various Venezuelan government officials (including President Nicolas Maduro) pursuant to Executive Order 13692 of March 8, 2015 (see prior blog post here regarding this order).

In a continuing effort to pressure and isolate North Korea by targeting entities and individuals in third countries, on Tuesday, August 22, 2017, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) and US Justice Department (“DOJ”) announced sanctions and a civil forfeiture action, respectively, targeting Chinese and Russian entities accused of directly or indirectly assisting or supporting North Korea’s nuclear and ballistic missile programs. China is North Korea’s primary trading partner and these actions appear to be an effort, in part, to ramp up pressure on China to assist in curtailing its neighbor’s nuclear ambitions.

Last month, the US Senate passed significant Russia sanctions legislation as an amendment to an Iran sanctions bill targeting Iran’s ballistic missile program. The Russia sanctions provisions sought to limit the President’s ability to relax existing US sanctions targeting Russia while imposing additional restrictions impacting various sectors of the Russian economy.  The key provisions of the Senate bill are summarized in our earlier blog post.