On January 16, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 5N, “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After April 16, 2024,” which continues to delay U.S. persons’ ability to enforce bondholder rights to the CITGO
Sanctions
OFAC Updates its Guidance on the Price Caps on Russian Oil and Russian Petroleum Products
On December 20, 2023, nearly eleven months after publishing its finalized guidance on the implementation of the twin price caps on Russian oil and Russian petroleum products, the Department of the Treasury (“Treasury”) published a revised Guidance on Implementation of the Price Cap Policy for Crude Oil and Petroleum Products of Russian Federation Origin. …
President Biden Authorizes Secondary Sanctions on Foreign Financial Institutions Facilitating Certain Transactions Involving Russia
On December 22, 2023, President Joseph Biden issued Executive Order 14114 (EO) amending EO 14024 by authorizing the imposition of U.S. sanctions on foreign financial institutions that are either facilitating significant transactions on behalf of persons designated for operating in certain key sectors of the Russian economy, or facilitating significant transactions or providing services involving Russia’s…
President Biden Expands U.S. Sanctions on Russia by Authorizing Additional Prohibitions on Imports of Russian Seafood and Diamonds
On December 22, 2023, President Joseph Biden amended, among other things, Executive Order (EO) 14068, by additionally authorizing the prohibition on the importation and entry into the United States, including a foreign trade zone located in the United States, of the following products of Russian Federation origin: fish, seafood, and preparations thereof, as well…
OFAC and State Sanction Over 250 Entities and Individuals in Connection with Russia’s War Against Ukraine
On December 12, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of State announced sanctions designating numerous additional Russian individuals and entities who have been determined to be assisting in the war against Ukraine and for efforts to evade U.S. sanctions and export controls on Russia. OFAC also…
OFAC and BIS Further Sanction Belarusian and Russian Entities and Individuals
On December 5, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of Commerce’s Bureau of Industry and Security (BIS) imposed sanctions on numerous entities and individuals in order to place additional pressure on both Belarus and Russia. The OFAC sanctions focus on Belarus’ “authoritarian regime” and for its…
OFAC Once Again Extends Venezuela General License for Limited Maintenance or Wind-Down of Transactions Involving PdVSA and Certain Entities
On November 16, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 8M, extending authorization until May 16, 2024 for certain activities previously authorized under General License 8L. General License 8M authorizes the continuation of transactions and activities “ordinarily incident and necessary to the limited maintenance of…
OFAC Issues Guidance for Provision of Humanitarian Aid to the Palestinian People
On November 14, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an important guidance document to ensure the provision of humanitarian aid to the Palestinian people in Gaza, while also maintaining strict controls to prevent funds from reaching Hamas. OFAC clarified that “U.S. sanctions do not stand in the…
OFAC, State and BIS Announce Further Sanctions on Companies Supporting Russia’s War Efforts
On November 2, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC), the Department of State, and the Department of Commerce’s Bureau of Industry and Security (BIS) announced a combined effort to designate and sanction numerous additional Russian individuals and entities who have been determined to be assisting in the war against…
OFAC Prohibits Financial Services with MOGE and Imposes Additional Sanctions on Persons and Entities Connected to Burma’s Military
On October 31, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a new directive prohibiting U.S. persons from providing certain financial services to Myanma Oil and Gas Enterprise (MOGE) and designated certain entities and individuals for connections to the Burma’s military regime.
Under Directive 1, issued pursuant to Executive…

