On March 31, 2020, the US Government issued a proposed framework for a peaceful democratic transition in Venezuela. The framework outlines 13 steps for a restructured Government of Venezuela (“GOV”) that, if followed, would lead to the lifting of US sanctions on the GOV, Petróleos de Venezuela, S.A. (“PdVSA”), and other GOV officials and agencies. The framework provides a total of 13 actions, including, among others: a full return of, and restoration of all powers…
On December 26, 2019, the US State Department’s Directorate of Defense Trade Controls (“DDTC”) published a long-awaited Interim Final Rule (the “Interim Rule”) revising a number of definitions in the International Traffic in Arms Regulations (“ITAR”). While DDTC was accepting comments until January 27, unless a new or revised rule is published, the Interim Rule will go into effect on March 25, 2020. These changes will permit companies storing and transmitting ITAR technical data to benefit from cloud computing and email services that utilize global platforms.
On September 9, 2019, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued Executive Order 13886 (“EO 13886”), expanding the US counter-terrorism sanctions program by amending Executive Order 13224 (“EO 13224”), which dates to the aftermath of the 9/11 terrorist attacks. OFAC also designated 28 individuals and entities as Specially Designated Global Terrorists (“SDGTs”) under this new authority and updated various other entries on the Specially Designated Nationals and Blocked Persons List to reflect sanction of those authorities under the same authority. In addition, as described in statements here and here, the State Department implemented the new authority by designating Hurras al-Din, an al-Qaeda-affiliated group in Syria, and 12 leaders of SDGT groups (all of which were designated by OFAC on the same day).
On September 4, 2019, the US Department of State published draft Guidance for the Export of Hardware, Software and Technology with Surveillance Capabilities and/or parts/know-how (the “Guidance”) to provide insight to exporters of items with surveillance capacities on human rights concerns to consider prior to export of such items. The State Department is soliciting feedback on the Guidance until October 4, 2019 for its consideration for the final version of the Guidance to be published at a later date (yet to be specified).