On December 9, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned two Chinese individuals and a vast network fishing vessels they control, including Pingtan Marine Enterprise Ltd. (PME) and Dalian Ocean Fishing Co., Ltd. (Dalian), for perpetrating serious human rights abuses and corruption via illegal, unreported, and unregulated (IUU) fishing. Although
Sanctions
Treasury Announces Price Cap on Russian Oil
On December 2, 2022, the Department of the Treasury (“Treasury”) issued a Determination pursuant to Executive Order 14071 of April 6, 2022 imposing a price cap of $60 per barrel on seaborne crude oil of Russian origin, effective December 5, 2022. Thus, companies can purchase and/or provide services related to the maritime transport of Russian-origin…
OFAC Issues General License Authorizing Chevron to Operate in Venezuela with PdVSA
On November 26, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela General License (GL) 41 authorizing all transactions ordinarily incident and necessary to certain activities for or related to the operation and management by Chevron Corporation or its subsidiaries (“Chevron”) of Chevron’s joint ventures in Venezuela (collectively, the “Chevron…
OFAC Again Extends Venezuela General License for Limited Maintenance or Wind-Down of Transactions Involving PdVSA and Certain Entities
On November 26, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 8K, extending authorization until May 26, 2023 for certain activities previously authorized under General License 8J. General License 8K authorizes the continuation of transactions and activities “ordinarily incident and necessary to the limited maintenance of…
OFAC Extends Russia-Related General License No. 8 Regarding Transactions Related to Energy
On November 10, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued amended Russia-related General License No. 8D extending the authorization to conduct transactions involving Vnesheconombank, Bank Financial Corporation Otkritie, Sberbank, VTB Bank, Alfa-Bank, and the Central Bank of Russia that are related to energy until May 15, 2023. The original…
Commerce, Treasury and State Departments Issue Joint Alert on Russia Sanctions and Export Controls
On October 14, 2022, the Departments of Commerce, Treasury and State issued a joint alert regarding the Impact of Sanctions and Export Controls on Russia’s Military-Industrial Complex. The alert provides a summary of the major actions taken by Treasury’s Office of Foreign Assets Control (OFAC) and Commerce’s Bureau of Industry and Security (BIS) with…
OFAC Expands Russia Sanctions Following Putin’s Illegal Annexation of Four Ukrainian Regions
On September 30, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated hundreds of Russian individuals and entities and placed them on the Specially Designated Nationals (SDN) List in response to Russia’s illegal annexation of additional Ukrainian territories.
The new designations target 14 suppliers connected to the country’s military-industrial complex, including…
Commerce Adds Numerous Russian Entities to BIS’ Entity List
On September 30, 2022, in response to Russia President Vladimir Putin’s illegal effort to annex further Ukrainian territory, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule that added 57 entities located in Russia and the Crimea region of Ukraine to the Entity List for supporting the Russian military’s continuing…
OFAC Sanctions Facilitators of Iranian Oil Sales
On September 29, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned a network of international companies for facilitating the sale of hundreds of millions of dollars’ worth of Iranian petrochemicals and petroleum products to South and East Asia. OFAC targeted the network, which includes a myriad of front companies in…
Annual Blocked Property Reports Due to OFAC by September 30
All U.S. persons and persons otherwise subject to U.S. jurisdiction, not only U.S. financial institutions, holding property blocked pursuant to various OFAC sanctions programs must file their annual reports on such blocked property by September 30, 2022. This report is pursuant to 31 C.F.R. §§ 501.603. This report must include all blocked property held as…

