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

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

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

Update on Section 889 Restrictions Relating to Telecommunications and Video Surveillance Services or Equipment from Certain Chinese Companies

Companies that do business with the US federal government have seen important changes to the requirements for federal contractors in the past several months as the US Federal Acquisition Regulatory Council (FAR Council) has proceeded with rulemaking for the implementation of Section 889 of the John S. McCain National Defense Authorization Act for Fiscal Year … Read more

OFAC Significantly Expands Sanctions on the Iranian Financial Sector

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

Recent Trends in Secondary Sanctions

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