On October 6, OFAC issued General License 5E, Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After January 19, 2021 (“GL-5E”). GL-5E appears intended to protect bondholders of CITGO Holding, Inc. (“Citgo”), which is a wholly owned subsidiary of Venezuela’s state-owned oil and natural gas company, Petróleos … Read more

On October 8, the U.S. Treasury Department imposed sweeping secondary sanctions on the financial sector of the Iranian economy, pursuant to Executive Order (“E.O.”) 13902.  Simultaneously, OFAC designated eighteen major Iranian banks to OFAC’s Specially Designated Nationals and Blocked Persons List (“SDN List”).  These new, broad sanctions apply to U.S. and non-U.S. persons, and appear … Read more

In recent years, OFAC has increasingly used secondary sanctions – the threat of being placed on a US sanctions list on the basis of dealings with US-sanctioned persons or jurisdictions – to attempt to regulate the conduct of non US persons. First utilized on a broad basis under OFAC’s Iran sanctions programs, secondary sanctions have … Read more

The Hong Kong Autonomy Act (HKAA),[1] enacted on July 14, 2020, authorizes a range of significant sanctions on persons and financial institutions in reaction to the new law on Safeguarding National Security in the Hong Kong Special Administrative Region (the HK National Security Law),[2] which came into force in Hong Kong on June 30, 2020. … Read more

As the United States continues its “maximum pressure” campaign on the Maduro regime in Venezuela, the US Department of Treasury’s Office of Foreign Assets Control (“OFAC”) has added 32 additional individuals, entities, and vessels to the Specially Designated Nationals (“SDN”) and Blocked Person List, from June to September 2020. The campaign is designed to cut … Read more

On October 1, both OFAC and the Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) published advisory guidance regarding the sanctions and money laundering risks, respectively, of making ransom payments to cybercriminal organizations which use “malware” to immobilize or compromise computer systems. The OFAC and FinCEN guidance signals that US regulators are likely to increase their … Read more

On Monday 3 August we published the second in our series of briefings on the Hong Kong National Security Law (NSL), focusing on the interaction between foreign sanctions laws and the NSL, and legislative measures taken by the US government to create a framework within which sanctions could be applied to Hong Kong or PRC parties. On … Read more

On August 5, 2019, President Trump issued a new Executive Order (“EO”), blocking all property and interests in property of the Government of Venezuela (defined to include the Central Bank of Venezuela and Petróleos de Venezuela (“PdVSA”)) in the US or in the possession of US persons. The EO also empowers the Secretary of Treasury, … Read more