OFAC Issues New Venezuela General License, Effectively Delaying Creditors’ Ability to Seize Citgo Assets

On October 6, OFAC issued General License 5E, Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After January 19, 2021 (“GL-5E”). GL-5E appears intended to protect bondholders of CITGO Holding, Inc. (“Citgo”), which is a wholly owned subsidiary of Venezuela’s state-owned oil and natural gas company, Petróleos … 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

Venezuela Update: Summer of Sanctions Sees Continuation of US Maximum Pressure Campaign in Venezuela

As the United States continues its “maximum pressure” campaign on the Maduro regime in Venezuela, the US Department of Treasury’s Office of Foreign Assets Control (“OFAC”) has added 32 additional individuals, entities, and vessels to the Specially Designated Nationals (“SDN”) and Blocked Person List, from June to September 2020. The campaign is designed to cut … Read more

OFAC, FinCEN Publish Ransomware Advisories

On October 1, both OFAC and the Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) published advisory guidance regarding the sanctions and money laundering risks, respectively, of making ransom payments to cybercriminal organizations which use “malware” to immobilize or compromise computer systems. The OFAC and FinCEN guidance signals that US regulators are likely to increase their … Read more

Summary of June 2020 Revisions to the US Department of Justice Corporate Compliance Programs Evaluation Guidance Document

On June 1, 2020, the United States Department of Justice (“DOJ”) substantially revised its guidance for evaluating the effectiveness of corporate compliance programs(the “Revised Guidance”). The new guidance contains several key recommendations which should be carefully reviewed by US and non US companies in order to ensure that their compliance programs meet DOJ’s expectations. Significantly, … Read more