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Venezuela

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On January 15, 2021, the Commerce Department’s Bureau of Industry and Security (BIS) published an interim final rule (“Rule”) amending various provisions of the Export Administration Regulations (EAR) to implement certain provisions of the Export Control Reform Act of 2018 (ECRA).  Among other things further outlined below, the Rule imposes new restrictions on specific activities of US persons. By way of brief background, the EAR generally controls transactions involving US origin items (i.e., goods, software, technology) regardless of whether…

On January 19, 2021, the Commerce Department published an interim final rule to implement President Trump’s 2019 Executive Order 13873 on “Securing the Information and Communications Technology and Services Supply Chain” (“Interim Rule”). The Interim Rule was issued following the closure of the public comment period on January 10, 2021 on the proposed rules issued on November 27, 2019 (“Proposed Rules”) to implement Executive Order 13873. For more information on Executive Order 13873 and the Proposed Rules, please see our blog…

On November 17, 2020, the US Treasury Department’s Office of Foreign Asset Control (OFAC) amended General License (“GL”) 8F and re-issued it as General License 8G. GL 8G extends the validity period of certain limited maintenance and wind-down transactions and activities involving Petróleos de Venezuela S.A. (“PdVSA”) until June 3, 2021. Our blog posts describing previous amendments to the general license are available here, here, here, and here. Specifically, GL 8G extends the validity period…

On October 29, 2020, the Commerce Department’s Bureau of Industry and Security (BIS) issued a final rule (the “final rule”) amending the license review policy under the Export Administration Regulations (EAR) for items controlled for national security (“NS”) reasons when destined to China, Russia, or Venezuela. The amendments add Venezuela to the list of countries to which the policy applies and modify the policy to replace the reference to military capabilities with a new, more nuanced standard…

On August 13, 2020, US Secretary of State Mike Pompeo issued a statement requesting that the US Department of Transportation (DOT) suspend private charter flights to all Cuban airports. This action will suspend all charter flights between the United States and Cuba over which the DOT exercises jurisdiction, except for authorized public charter flights to and from Havana and other private charter flights authorized for limited purposes. Secretary Pompeo’s statement cites the Administration’s intent to deny economic resources to…

On April 28, 2020, the Department of Commerce’s Bureau of Industry and Security (BIS) published two new final rules and a proposed rule in the Federal Register amending the Export Administration Regulations (EAR) to tighten restrictions on exports of technology to China, Russia, and Venezuela. According to Commerce Secretary Wilbur Ross, these actions are intended to combat efforts by entities in China, Russia, and Venezuela to use certain US technologies obtained through civilian supply chains…

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…

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 October 21, 2019, the US Commerce Department’s Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) to further restrict exports and reexports of items to Cuba (“the Amendment“). According to BIS, the Amendment was made to further restrict the Cuban government’s access to items subject to the EAR, thereby supporting the US government’s national security and foreign policy decision to hold the Cuban regime accountable for its repression of the Cuban people…