OFAC Publishes Guidance on “Communist Chinese Military Companies”

As noted in our previous post, Executive Order 13959 (“Addressing the Threat from Securities Investments that Finance Communist Chinese Military Companies”) (EO 13959 or Order), dated November 12, 2020, targets “Communist Chinese military compan[ies]” (CCMCs) by blocking “any transaction in publicly traded securities, or any securities that are derivative of, or are designed to provide … Read more

The US Government Rescinds Sudan’s State Sponsor of Terrorism Designation

On December 14, the US Department of State removed Sudan from the US State Sponsors of Terrorism List (“SST List”). The State Department explained that, “[t]his achievement was made possible by the efforts of Sudan’s civilian-led transitional government to chart a bold new course away from the legacy of the Bashir regime and, in particular, … Read more

OFAC Introduces Non-SDN Menu-Based Sanctions List

On December 14, OFAC published a new “Non-SDN Menu Based Sanctions List.” The publication is designed to be a reference tool that identifies individuals and entities subject to certain non-blocking menu-based sanctions. OFAC’s publication is available here. “Menu-based” sanctions authorize the relevant agency to select one or more sanctions from a menu of options. OFAC … Read more

EU introduces global human rights sanctions regime

On 7 December 2020, the Council of the EU announced the introduction of a new global human rights sanctions regime, as part the EU Action Plan on Human Rights and Democracy 2020-2024. The new regime introduces a framework to impose a travel ban and asset freeze on individuals and entities identified as responsible for, involved … Read more

OFAC Sanctions Chinese Tech Company for Violating Venezuela Sanctions

On November 30, OFAC designated China National Electronics Import and Export Corporation (“CEIEC”) to its Specially Designated Nationals and Blocked Persons list (“SDN List”). The OFAC press release is available here. CEIEC is a Chinese state-owned technology corporation. According to its website, CEIEC claims that it is a “close partner of many foreign government[s], military … Read more

US Federal Agencies Continue the US “Maximum Pressure” Campaign

In series of coordinated actions and announcements during the course of October and November 2020 (the Recent Iran Actions), three US federal agencies—the US Department of State (DOS), the Office of Foreign Assets Control (OFAC) of the US Department of the Treasury, and the US Department of Justice (DOJ)—targeted both Iranian and non-Iranian entities and … Read more

OFAC Extends Venezuela General License 8, Enabling US Energy Companies to Continue Engaging in Limited Activities With PdVSA

On November 17, OFAC issued General License 8G, Authorizing Transactions Involving Petróleos de Venezuela, S.A. (“PdVSA”) Necessary for the Limited Maintenance of Essential Operations in Venezuela or the Wind Down of Operations in Venezuela for Certain Entities (“GL 8G.”). GL 8G, like its predecessor General License No. 8F (“GL 8F”), authorizes several  US energy companies … Read more

United States imposes new restrictions on securities of companies allegedly linked to the Chinese military

In a significant new Executive Order (“Addressing the Threat from Securities Investments that Finance Communist Chinese Military Companies”) (Order) issued on November 12, 2020, the current US Administration has prohibited “any transaction” in either the “publicly traded securities,” or “derivative[s]” of securities of companies determined to be “Communist Chinese military compan[ies]” by US authorities. Thirty-one … Read more