On December 22, 2020, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) formally added the Central Bank of Syria (CBoS) to the Specially Designated Nationals (SDN) List. While OFAC notes that the bank is “already blocked as meeting the definition of the Government of Syria in [Executive Order] 13582 and the Syrian
Sanctions
OFAC Sanctions Three Cuban Entities for Ties to Cuban Military
On December 21, 2020, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned three entities it has identified are controlled by the Cuban military and that have “strategic roles in the Cuban economy.” OFAC has placed the following three entities on the Specially Designated Nationals (SDN) List: (1) Grupo de Administración Empresarial…
Treasury Issues First Report on Foreign Financial Institutions Under the Hong Kong Autonomy Act
On December 11, 2020, the Treasury Department submitted its first report to Congress under the Hong Kong Autonomy Act, stating that to date it has not identified any foreign financial institutions (FFIs) that have knowingly conducted a significant transaction with an identified foreign person under the Hong Kong Autonomy Act (HKAA). The Department of…
U.S. Rescinds Sudan’s Designation as State Sponsor of Terrorism
On December 14, 2020, the State Department announced that the United States was rescinding Sudan’s designation as a State Sponsor of Terrorism. The brief statement indicated that this removal “represents a fundamental change in our bilateral relationship toward greater collaboration and support for Sudan’s historic democratic transition. This achievement was made possible by the efforts…
U.S. and Ecuador Update Trade and Investment Council Agreement
On December 8, 2020, the United States and Ecuador signed a new Protocol on Trade Rules and Transparency that updates the U.S.-Ecuador Trade and Investment Council Agreement (TIC Agreement). The Protocol adds four new annexes on (i) Customs Administration and Trade Facilitation, (ii) Good Regulatory Practices, (iii) Anticorruption and (iv) Small and Medium-Sized Enterprises. In…
Additional Chinese Military Companies Listed Under Section 1237 and Subject to Investment Ban
On December 3, 2020, the Department of Defense (DOD) released the names of four additional “Communist Chinese military companies” operating directly or indirectly in the United States in accordance with the statutory requirement of Section 1237 of the National Defense Authorization Act (NDAA) for Fiscal Year 1999, as amended. The companies are:
- China Construction Technology
…
OFAC Issues Venezuela General License No. 8G to Continue Authorization of Limited Transactions Involving PdVSA and Winding Down of Operations for Certain Entities
On November 17, 2020, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related 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.” This general license continues to…
OFAC Restricts Remittances to and from Cuba to Exclude Entities on Cuba Restricted List
On October 27, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published a final rule in the Federal Register amending the Cuban Assets Control Regulations (CACR) to remove from the scope of generally authorized remittances any transactions involving “entities or subentities” identified on the U.S. Department of State’s Cuba Restricted…
U.S. and Brazilian Governments Update Agreement on Trade and Economic Cooperation
On October 19, 2020, the United States and Brazil agreed to an updated protocol for the 2011 Agreement on Trade and Economic Cooperation (ATEC) with three new annexes: Customs Administration and Trade Facilitation, Good Regulatory Practices, and Anticorruption. U.S. Trade Representative Robert Lighthizer said that the protocol “uses the existing ATEC to establish common standards…
State Department Issues Hong Kong Autonomy Act Report
On October 14, 2020, pursuant to the Hong Kong Autonomy Act (HKAA), the State Department submitted to Congress a report identifying foreign persons “who are materially contributing to, have materially contributed to, or attempt to materially contribute to the failure of the People’s Republic of China (China) to meet its obligations under the Sino-British Joint…

