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Trade Sanctions

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On May 19, the US Commerce Department’s Bureau of Industry and Security (BIS) issued an interim final rule effective on May 15, 2020, amending the Export Administration Regulations’ (EAR) General Prohibition Three (the “foreign-produced direct product rule”) and Entity List to impose new controls on the reexport, export from abroad, and transfer (in-country) of certain foreign-produced semiconductor-related items when such items are the direct product of certain designated US technology or software and are destined to Huawei…

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.  Read more on our Sanctions & Export Controls Update.

On April 3, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) re-issued and extended General License No. 13E (“GL 13E”) to continue the validity period for transactions concerning Nynas AB and its subsidiaries (“Nynas”) that otherwise would be prohibited under Executive Order 13850 or Executive Order 13884 given Nynas’s 50% indirect ownership by Petróleos de Venezuela S.A. (“PdVSA”). The authorization was extended through 12:01 am EST on May 14, 2020. In a note accompanying GL 13E’s issuance…

What has changed? On March 11, 2020, the Congressional-Executive Commission on China (“CECC”) announced new proposed legislation, the Uyghur Forced Labor Prevention Act, co-sponsored by the chairs of the CECC, Rep. Jim McGovern (D – MA) and Sen. Marco Rubio (R – FL), targeting supply chains linked to forced labor in the Xinjiang Uyghur Autonomous Region in China. The Uyghur Forced Labor Prevention Act would establish a rebuttable presumption that all labor occurring in Xinjiang, China,…

The US Treasury Department’s Office of Foreign Assets Control (OFAC) has issued an FAQ providing guidance relating to the provision of humanitarian goods and assistance to Iran in response to the Coronavirus Disease 2019 outbreak there. The guidance summarizes existing legal authorities that may authorize such humanitarian activities, which include: The making of humanitarian donations from the US or by US persons to recipients in Iran (other than to the Government of Iran, persons on OFAC’s SDN…

On March 5, 2020, pursuant to Executive Order 13851 of November 27, 2018 and the Nicaragua Human Rights and Anticorruption Act of 2018, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) further escalated sanctions against Nicaragua by naming the Nicaraguan National Police (“NNP”) and three NNP commissioners as Specially Designated Nationals (“SDNs”), citing serious human rights abuses. OFAC previously named other officials of the NNP as SDNs in 2018 and 2019, also citing human rights abuses. The press release issued by…

On January 27, 2020, the US Treasury Department’s Office of Foreign Assets Control (OFAC) issued a new Counter Terrorism and Iran-related General License No. 8 (“GL 8”) together with new frequently asked questions (“FAQs”) about the general license and the Swiss Humanitarian Trade Arrangement (“SHTA”). New GL 8 authorizes US Persons and non-US entities owned or controlled by US Persons to engage in Iran-related humanitarian transactions even if the CBI is directly or indirectly involved. Although the US Government…

On February 18, 2019, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), pursuant to Executive Order (“EO”) 13850, designated Rosneft Trading S.A., the Swiss-incorporated, Russian-controlled oil brokerage firm, as a Specially Designated National (“SDN”) for operating in the oil sector of the Venezuelan economy. OFAC also designated the President and Chairman of Rosneft Trading S.A., Didier Casimiro, as an SDN for purporting to act for or on behalf of, directly or…

On February 14, 2020, the Department of State published in the Federal Register a notice [Public Notice: 11034] that measures imposed pursuant to Section 3 of the Iran, North Korea, and Syria Nonproliferation Act (the Act) described in this notice against 13 persons went into effect February 3, 2020. A determination has been made that a number of foreign persons have engaged in activities that warrant the imposition of measures pursuant to Section 3 of…

On February 7, 2020, the Office of Foreign Assets Control (OFAC) published in the Federal Register a final rule adding regulations (31 C.F.R. Part 355) to implement Executive Order 13882 of July 26, 2019 (“Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Mali”). OFAC intends to supplement these regulations with a more comprehensive set of regulations, which may include additional interpretive and definitional guidance, general licenses, and statements of licensing…