On January 15, 2021, the US Department of Commerce’s Bureau of Industry and Security (BIS) published an Interim Final Rule imposing new restrictions requiring licenses for certain transactions involving “military-intelligence end uses” or “military-intelligence end users” in China, Russia, Venezuela or a country listed in Country Group E:1 or E:2. It is important to note … Continue Reading
What are international sanctions? What are primary and secondary sanctions? What are extraterritorial effects and how will that impact multinational operations? The changing international sanctions regulations produce dizzying regulatory landscape, and complex as well as confusing compliance environment. To help lift the curtain a bit on this topic, Trade Practitioner José María Viñals (partner, Madrid/Brussels), also … Continue Reading
On December 23, 2020, the US Department of Commerce, Bureau of Industry and Security (BIS) published in the Federal Register a Final Rule that identified 57 Chinese companies and 45 Russian companies as “military end users,” limiting their ability to purchase certain US goods and technology (MEU List).… Continue Reading
The latest edition of our transatlantic export controls and sanctions update is available. In this publication, we look at the shifting regulatory framework for international trade compliance on both sides of the Atlantic. In this issue, we cover:… Continue Reading
On April 28, 2020, the US Department of Commerce’s Bureau of Industry and Security (BIS) published in the Federal Register a Final Rule amending the Export Administration Regulations (EAR), 15 CFR parts 730-774. This new rule critically expands the licensing requirements for exports, reexports and transfers (in-country) of items subject to the EAR in three … Continue Reading
OFSI, part of the HM Treasury, working toward ensuring that financial sanctions are properly implemented and enforced in the UK, has updated numerous financial sanctions that are currently in force. The recent updates are for financial sanctions in the following regions and industries: ISIL/Da’esh and Al-Qaida Organizations Nicaragua Venezuela Central African Republic Ukraine – Sovereignty and Territorial Integrity Syria Libya … Continue Reading
Recently, the Department of the Treasury’s OFAC issued an amended General License 8D, “Authorizing Transactions Involving Petróleos de Venezuela, S.A. (PdVSA) Necessary for Maintenance of operations for Certain Entities in Venezuela.”… Continue Reading
On October 18, 2019, the Bureau of Industry and Security (BIS) of the US Department of Commerce announced that it will further restrict the Cuban regime’s access to goods, including commercial aircraft. This action is in response to Cuba’s domestic situation, as well as its support of the Maduro regime in Venezuela. … Continue Reading
On August 5, 2019, President Trump signed a new Venezuela-related Executive Order (EO), which imposes additional sanctions on the government of Venezuela. … Continue Reading
On January 28, 2019, the Department of Treasury’s Office of Foreign Assets Control (OFAC) announced that it has designated Petroleos de Venezuela, S.A. (PdVSA) following Executive Order (E.O.) 13850, after a determination by Treasury Secretary Steven T. Mnuchin and Secretary of State Michael Pompeo that PdVSA was operating in the Venezuelan oil sector. Additionally, OFAC has amended General License 3 and … Continue Reading
On January 8, 2019, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 6, which authorizes the winding down of certain specified transactions with Globovision Tele C.A. and Globovision Tele CA, Corp. until January 8, 2020. Additionally, OFAC issued new FAQs for General License 6, and also added several new individuals and entities to … Continue Reading
The EU updated the list of national authorities participating in the Kimberley Process certification scheme for trade in rough diamonds. The list also includes the competent authorities of Venezuela that were readmitted to participate in this scheme. (Commission Implementing Regulation (EU) 2018/578)… Continue Reading
On 19 March, the President issued Executive Order (EO) 13827, Taking Additional Steps to Address the Situation in Venezuela. This EO prohibits US persons from engaging in all transactions related to, provision of financing for and other dealings in any digital currency, digital coin or digital token that was issued by, for or on behalf of the government of Venezuela … Continue Reading
On 5 January 2018, OFAC designated four current or former Venezuelan government offcials pursuant to EO 13692 for their alleged role in undermining electoral processes, media censorship, or corruption in government-administered food programs in Venezuela. Included among the individuals designated was Rodolfo Clemente Marco Torres, who is an External Director on the Board of Directors … Continue Reading
On 6 December 2017, the Venezuela (European Union Financial Sanctions) Regulations 2017 entered into force in the UK. This regulation implements Council Regulation (EU) 2017/2063 of 13 November 2017 and provides for the imposition of restrictive measures on persons or entities considered to be involved in undermining democratic principles and the rule of law, as … Continue Reading
On 22 January 2018, the EU froze the assets of seven Venezuelan officials, notably including the Minister for Interior, the head of the Intelligence Service, the head of the National Electoral Council and the President of the Supreme Court of Justice. These individuals are considered by the EU to be “involved in the non-respect of … Continue Reading
The US Department of Treasury’s Office of Foreign Assets Control (OFAC) has published two new Frequently Asked Questions (FAQ) concerning economic sanctions adopted in August against the Government of Venezuela, under Executive Order (EO) 13808. The first FAQ explains the treatment of Petroleos de Venezuela, S.A. (PdVSA), a state-owned entity, under EO 13808. The second … Continue Reading
In November, the UK passed the Venezuela (European Union Financial Sanctions) Regulations 2017. The regulations follow the EU’s recent sanctions on Venezuela as part of Council Regulation (EU) 2017/2063. They cover offences, penalties and other provisions, such as reporting obligations. On 15 November, the UK Department for International Trade published a notice to exporters (Notice … Continue Reading
On 13 November, the Foreign Affairs Council of the EU adopted conclusions on Venezuela, including the imposition of an arms embargo. On the back of a UN report that described a “worsening human rights situation … within a wider severe economic and social crisis in the country and an increasingly unstable and polarized national political … Continue Reading
On 13 February, the Office of Foreign Assets Control (OFAC) published the names of two individuals and 13 entities designated for blocking sanction under the Kingpin Act for involvement in narcotics trafficking. These included Venezuelan Vice President Tareck Zaidan El Aissami Maddah, and his business partner Samark Jose Lopez Bello, and a network of US and … Continue Reading
Iran – Legislative Action on New Restrictions. On the one-year anniversary of the Joint Comprehensive Plan of Action (JCPOA) Thursday, President Obama issued a statement saying: “[T]he Iran Deal has succeeded in rolling back Iran’s nuclear program, avoiding further conflict and making us safer.” Senate Foreign Relations Committee (SFRC) Chairman Bob Corker (R-Tennessee), along with … Continue Reading
G-7 Leaders’ Declaration. The G-7 Leaders’ Declaration issued on Friday from Ise-Shima, Japan, touched on topics such as the global economy, trade, maritime security, cyberspace, anti-corruption, infrastructure, global health challenges, climate change and female empowerment. The Leaders advocated TPP member states ratify the agreement, while also addressing the global excess steel capacity issue, government subsidies … Continue Reading
