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

OFAC Sanctions Russian Government Research Institution Connected to the Triton Malware

On October 23, OFAC designated State Research Center of the Russian Federation FGUP Central Scientific Research Institute of Chemistry and Mechanics (TsNIIKhM) to OFAC’s Specially Designated Nationals and Blocked Persons List because of TsNIIKhM’s involvement with Triton malware. TsNIIKhM is a Russian government-controlled research institution. OFAC’s press release is available here. The 2017 Triton Malware … Read more

President Issues New Iran EO, Broadening Secondary Sanctions Triggers, and E3 Trigger JCPOA Dispute Resolution Mechanism

In a significant intensification of US “secondary sanctions” against Iran, on January 10, 2020, President Trump issued an Executive Order (“EO”) that authorizes the imposition of US sanctions on persons or entities “operating in” the Iranian construction, mining, manufacturing, and textiles sectors, or which engage in “significant transactions” in those sectors. On the same day, … Read more