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On November 24, OFAC issued General License 8I, 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 8I.”). GL 8I is available here. GL 8I replaces and supersedes General License No. 8H (“GL 8H”), … Read more
In a special podcast cross over event, the Designated team joins The Bettor’s Verdict to discuss the Impact of Crypto on Sanctions and AML Laws in the United States. In this episode, Designated host Jonathan Cross, is joined by The Bettor’s Verdict host Steve Jacobs, and Herbert Smith Freehills Partner John O’Donnell. Jonathan, Steven and … Read more
In August 2021, we published a post about the European Commission’s roadmap / inception impact assessment in relation to its review of the current Blocking Statute (Regulation 2271/96). On 31 August 2021, the European Commission closed the initial feedback period for this impact assessment and, as a next step, has now launched a public consultation process seeking further feedback … Read more
In this episode, Jonathan Cross, Brittany Crosby-Banyai and Dan Hudson discuss the history of the Iran sanctions program under the Iranian nuclear deal, known as the Joint Comprehensive Plan of Action (“JCPOA”). They also analyze the mechanisms by which sanctions were re-imposed when the US left the agreement. These considerations offer insight as to the … Read more
On June 21, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated sixteen individuals and five entities pursuant to Executive Order (“E.O.”) 13405 of June 16, 2006, entitled “Blocking Property of Certain Persons Undermining Democratic Processes or Institutions in Belarus.” According to a press release, OFAC designated these individuals and … Read more
On January 11, the US Department of State (“State Department”) re-designated Cuba to the US State Sponsors of Terrorism List (“SST List”) for “repeatedly providing support for acts of international terrorism in granting safe harbor to terrorists.” Notably, the Trump administration announced the decision shortly before the inauguration of President-elect Biden. The decision to re-designate … Read more
As noted in our previous posts in November and December 2020, the current US Administration has targeted certain alleged “Communist Chinese military companies” (CCMCs) via Executive Order (EO) 13959 (“Addressing the Threat from Securities Investments that Finance Communist Chinese Military Companies”) (EO 13959 or Order), dated November 12, 2020. EO 13959 prohibits US persons from engaging in … Read more
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
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
