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Financial institutions face an increasingly complex sanctions compliance environment. Sanctions are increasingly emerging at the forefront of compliance agendas given the proliferation of new restrictions and counter-measures, together with increasingly aggressive enforcement action extra-territorially. This is impacting both financial institutions and their clients, leading to expectations for more robust compliance programs for both. This has been acutely felt most recently in the Middle East following the USD 100 million sanctions fine against a Dubai based…

On 31 December 2020, the UK’s Brexit transition period with the EU ended, and the UK became a third country with respect to the EU from a sanctions and export controls perspective. The UK now has its own autonomous sanctions and export control regimes – closely related to the EU’s regimes, but with important differences and complexities that clients need to be aware of. We have written an alert that summarises the key considerations for companies in…

On October 8, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) identified the Iranian financial sector as subject to Executive Order (“EO”) 13902 and, based on such identification, designated 18 Iranian banks.  Our previous blog post on EO 13902 is available here.  OFAC also issued a general license and Iran-related Frequently Asked Questions, as further described below.  The action represents a significant escalation of the sanctions targeting Iran’s financial sector, yet many…

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.