Sanctions

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that it has issued General License (“GL”) 5D (Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After October 20, 2020), which continues to delay U.S. persons’ ability to enforce bondholder rights to the CITGO…

On June 25, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that its recent designations to the Specially Designated Nationals and Blocked Entities (SDN) List targeted Iran’s steel, aluminum, copper, and iron sectors. OFAC designated eight entities operating in the Iranian metals sector including companies from Iran, the United…

On June 26, 2020, the State Department issued a Federal Register notice announcing that it has sanctioned certain Syrian individuals and entities it has determined “are responsible for or complicit in, have directly or indirectly engaged in, attempted to engage in, or financed, the obstruction, disruption, or prevention of a ceasefire in northern Syria”  or…

The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced that it has issued General License (“GL”) 37  (Authorizing the Wind Down of Transactions Involving Delos Voyager Shipping Ltd, Romina Maritime Co Inc, and Certain Vessels), which expires on July 21, 2020.   Additionally, OFAC issued frequently asked question (“FAQ”) 834 addressing the…

On June 8, 2020, the State Department announced sanctions against the Islamic Republic of Iran Shipping Lines (IRISL) and its Shanghai-based subsidiary, E-Sail Shipping Company Ltd (E-Sail) pursuant to Executive Order 13382, which targets weapons of mass destruction (WMD) proliferators and supporters.  In a press statement, Secretary of State Mike Pompeo noted that,…

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has issued four new Frequently Asked Questions​​ (FAQs) related to Executive Order (E.O.) 13902, “Imposing Sanctions With Respect to Additional Sectors of Iran.”  The FAQs address the manufacture of medicines, medical equipment and sanitation products in Iran, the scope of sectors targeted…

On June 3, 2020, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued new regulations under 31 CFR Part 569 to implement Executive Order (E.O.) 13894 issued by President Trump on October 14, 2019.  The President issued E.O. 13894 in response to the situation in and around Syria, in particular, the military…

Hong Kong currently enjoys special trade status with the United States in comparison to China, as a result of China’s agreement in 1997 to allow Hong Kong continued autonomy in many economic and administrative ways. As recent press articles have indicated, the People’s Republic of China (PRC) has increasingly cracked down on the Hong Kong…

The U.S. Department of Justice unsealed an indictment charging 28 North Korean and 5 Chinese individuals (“Defendants”) with facilitating more than $2.5 billion in illegal payments for Pyongyang’s nuclear weapons and missile program through North Korea’s state-owned Foreign Trade Bank (“FTB”). DOJ alleges that the scheme involved “covert branches” of FTB in China, Russia, Libya,…

On May 27, 2020, Secretary of State Mike Pompeo announced that the United States was ending the sanctions waiver pertaining to the remaining nuclear projects in Iran covered by the Joint Comprehensive Plan of Action (JCPOA) – the Arak reactor modernization conversion, the provision of enriched uranium for the Tehran Research Reactor, and the export…