On September 4, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a revised Russia General License (GL) 25E that continues to authorize all transactions ordinarily incident and necessary to the receipt or transmission of telecommunications involving the Russian Federation. This continues to allow for services incident to the exchange of
Sanctions
On the Eve of Ukrainian Independence Day, the United States Expands Export Controls and Sanctions on Russia and Belarus
On August 23, 2024—one day before Ukrainian Independence Day—the Department of Commerce’s Bureau of Industry and Security (BIS), the Department of the Treasury, and the Department of State commemorated the milestone by expanding U.S. export controls and sanctions on Russia and Belarus. Notably, the agencies’ actions also come amidst Ukraine’s surprise incursion into Russia’s Kursk…
OFAC Implements Further Sanctions on Belarus
On August 9, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned 19 individuals and 14 entities for their continued support of “Russia’s war in Ukraine through military resource production and transshipment of goods to Russia, sanctions evasion on behalf of Belarusian defense entities, and revenue generation for Belarusian oligarchs in…
OFAC Issues Another Extension of Venezuela General License Delaying PdVSA 2020 8.5% Bond-Related Authorizations
On August 12, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 5P, “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After November 12, 2024,” which continues to delay U.S. persons’ ability to enforce bondholder rights to the CITGO…
OFAC Extends Wind Down Authorization for Transactions with Certain Russian Financial Exchanges
On August 2, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued two revised general licenses regarding conducting financial transactions involving: (i) the Moscow Exchange (MOEX), Russia’s largest public trading markets for equity, fixed income, derivative, foreign exchange, and money market products, as well as Russia’s central securities depository and the…
OFAC Continues to Extend Authorizations Under Russia General License 13
On July 10, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) again extended previous Russia-related General License (GL) 13 by issuing a revised GL 13J, “Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024,” which states that U.S. persons are authorized to pay taxes, fees, or import…
OFAC Issues General License 40C Continuing to Authorize Certain Transactions Involving the Export of LP Gas to Venezuela
On July 8, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 40C, “Authorizing Certain Transactions Involving the Exportation or Reexportation of Liquefied Petroleum Gas to Venezuela.” This revised general license continues authorization of all transactions and activities related to the exportation or reexportation, directly or indirectly…
OFAC and BIS Significantly Extend Sanctions and Export Control Restrictions Against Russia and Belarus
- New sanctions and export controls on Russia and Belarus became effective June 12, 2024.
- New OFAC prohibition on certain IT and software services to Russia begins September 12, 2024.
- Hundreds of individuals and entities designated as SDNs for supporting Russia’s war efforts.
- New license requirements for certain software exports to Russia and Belarus
Commerce and Treasury Departments Announce New Sanctions and Export Control Restrictions on Russia and Belarus
On June 12, 2024, the Office of Foreign Assets Control (OFAC) and the Bureau of Industry and Security (BIS) announced new sanctions and export control restrictions on Russia and Belarus. These measures have significant implications for companies that do business with or in these regions, as they may face new licensing requirements, limitations, or prohibitions…
OFAC Again Extends Venezuela General License for Limited Maintenance or Wind-Down of Transactions Involving PdVSA and Certain Entities
On May 10, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 8N, extending authorization until November 15, 2024 for certain activities previously authorized under General License 8M. General License 8N authorizes the continuation of transactions and activities “ordinarily incident and necessary to the limited maintenance of…

