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On November 5, 2019, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued a new Venezuela-related general license (General License No. 35) (“GL 35”) to authorize certain administrative transactions with the Government of Venezuela (“GOV”) prohibited by Executive Order (“EO”) 13884 (“Blocking Property of the Government of Venezuela”); issued General License No. 34A (“GL 34A”), which supersedes and replaces General License No. 34, and authorizes transactions involving certain GOV-related individuals prohibited by EO 13884; and identified five current GOV officials on the Specially Designated Nationals and Blocked Persons List (“SDN List”) pursuant to EO 13884.

Then, on November 21, 2019, OFAC announced the amendment of the Venezuela Sanctions Regulations (“VSR,” 31 C.F.R. Part 591) to incorporate additional EOs; make certain clarifying changes; add a GL authorizing US Government activities; and add an interpretive provision regarding activities related to judicial processes.  The VSR regulatory amendments took effect on November 22, 2019 concurrent with their publication in the Federal Register, available here.

These Venezuela sanctions developments are described in more detail below.  Our previous blog posts about US sanctions targeting Venezuela are available here.

Who Should Attend? In-house legal and compliance specialists working within the technology, media and telecoms sectors.

Speakers from Baker McKenzie’s Global Trade & Commerce, Compliance & Investigations, Antitrust & Competition, IPTech, and TMT Groups will discuss managing compliance risks in the context of the Technology, Media & Telecoms sector. We will have speakers from the UK, elsewhere in Europe, the US and Asia. Key topics will include:

  • Developments, risks and practical considerations for the TMT sector regarding sanctions, export controls, customs, anti-bribery and corruption, anti-money laundering, tax evasion, antitrust and competition, data privacy, consumer protection, cyber security and human rights
  • Practical sessions on best practices in the TMT sector for managing compliance risks in the context of (1) the cloud; (2) M&A deals; and (3) the supply chain, including the impact of Brexit and global trade wars.

Please click here for the full agenda.

On October 31, 2019, the US State Department strengthened US secondary sanctions targeting Iran under the Iran Freedom and Counter-Proliferation Act of 2012 (“IFCA”) (codified at 22 U.S.C. § 8801 et seq.), which dates back to 2013.  These new IFCA sanctions target the construction sector in Iran and make sanctionable the export to Iran of certain strategic metals.