Biden Administration Rescinds Re-Imposition of UN Sanctions, Calls for Renewed JCPOA Negotiations with Iran

On February 18, 2021, the Biden Administration rescinded the United States’ re-imposition of United Nations sanctions against Iran, which were lifted as part of the Iran nuclear deal known as the Joint Comprehensive Plan of Action (“JCPOA”). The rescission is another step in the Biden Administration’s continuing efforts to have the United States re-join the … Read more

OFAC De-designates Ansarallah, Completing Reversal of Trump Administration Yemen Policy

On February 16, 2021, the US Department of Treasury’s Office of Foreign Assets Control (“OFAC”) revoked the designations of Ansarallah, the Yemeni political and para-military organization also known as the Houthis, under the Global Terrorism Sanctions Regulations (“GTSR”), the Foreign Terrorist Organization Sanctions Regulations (“FTOSR”), and Executive Order 13244. As a result, US persons no … Read more

Upcoming Webinar: Sanctions Under the New Administration

The Herbert Smith Freehills global sanctions team invites you to join them for a webinar, to discuss: potential US sanctions implications of the impending change of Administration with respect to Venezuela, China and Russia-related sanctions, as well as the prospects for increased general emphasis on human rights and anti-corruption issues in US sanctions and trade … 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

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

OFAC Issues Advisory Highlighting Sanctions Risks Arising from Transactions Involving High-Value Artwork

On October 30, OFAC published an advisory (the “Advisory”), which highlights sanctions risks arising from transactions involving high-value artwork associated with persons on OFAC’s List of Specially Designated Nationals and Blocked Persons (“SDNs”). OFAC suggests that “high-value artwork” generally includes artwork with an estimated market value of more than $100,000 USD. OFAC explains that certain … Read more