Yesterday the Office of Foreign Assets Control (OFAC) formally rescinded General License H, requiring foreign subsidiaries of U.S. companies to wind down remaining business related to Iran by 11:59 pm EST on November 4, 2018.  After that date, foreign subsidiaries of U.S. companies and other owned or controlled entities will generally be prohibited from conducting any business related to Iran, including wind down activity.  This action was required following the President’s announcement on May 8 that the United States would withdraw from the multilateral Iran nuclear deal (the Joint Comprehensive Plan of Action or JCPOA).

OFAC issued amended FAQs and replaced General License H with a new Section 560.537 to the Iranian Transactions and Sanctions Regulations (ITSR, 31 C.F.R. Part 560) authorizing the following wind down activities related to foreign subsidiaries’ business with Iran:
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According to Bloomberg, the Trump administration is considering using the International Emergency Economic Powers Act (IEEPA) to block Chinese investments in industries or technologies “deemed important” to the U.S.  (This statute has been used primarily to authorize economic sanctions and embargoes administered by the Office of Foreign Assets Control).  To utilize IEEPA, the President

The President signed a new Executive Order today making it unlawful to engage in transactions involving digital currency issued by the Venezuelan government.  The Executive Order makes official prior guidance from the Office of Foreign Assets Control (OFAC), which stated that dealings related to Venezuelan digital currency would likely be prohibited under existing sanctions.

Last

The Office of Foreign Assets Control (OFAC)’s new North Korea Sanctions Regulations become effective today.  In addition to making certain technical and conforming changes, the newly updated Part 510 incorporates recent changes to the sanctions program under Executive Orders (E.O.) 13687, 13722, and 13810, the North Korea Sanctions and Policy Enhancement Act of 2016, and the Countering America’s Adversaries Through Sanctions Act of 2017 (CAATSA).  The new rules incorporate general licenses that were previously exclusively on OFAC’s website and make changes to those general licenses, including a new $5,000 cap on authorized remittances to North Korea and the elimination of the general license authorizing certain educational activities.  OFAC also issued four new general licenses authorizing certain transactions relating to the investment and reinvestment of funds, payments of certain legal fees, and the activities of the U.S. government and international organizations.

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Today the U.S. Office of Foreign Assets Control (OFAC) issued new sanctions targeting the shipping industry for dealings involving North Korea.  The sanctions include the designation of 56 companies and vessels involved in conducting illegal trade with North Korea.

OFAC also issued new guidance for the global shipping and finance industries, describing common methods used

Under Section 231 of the Countering America’s Adversaries Through Sanctions Act (CAATSA), the Trump administration was due to issue secondary sanctions on non-U.S. persons that conduct significant transactions with Russia’s defense and intelligence sectors.  The Trump administration declined to issue those new sanctions, claiming that CAATSA was serving as an effective deterrent – discouraging non-U.S. entities from doing business with the Russian defense and intelligence sectors – and that no new sanctions were needed at this time. 
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Last week, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) blacklisted 21 individuals and nine entities for various reasons, including involvement in the ongoing conflict in eastern Ukraine, connections to the Crimea region (which is subject to a complete U.S. embargo), and links to the Russian government.  Several of the newly minted Specially Designated Nationals (SDNs), including Russian engineering company Technopromexport, were allegedly involved in diverting Siemens-made gas turbines to Crimea in potential violation of European Union sanctions rules.  OFAC also added twelve subsidiaries of Surgutneftegaz to the Sectoral Sanctions Identification List, clarifying that the entities are subject to the energy-sector sanctions described in Directive 4 to E.O. 13662.
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On December 20, 2017, the President issued Executive Order 13818 implementing new sanctions against human rights abusers and persons involved in corruption pursuant to the Global Magnitsky Human Rights Accountability Act (Global Magnitsky Act).  The Global Magnitsky Act allows the U.S. government to target persons and entities involved in gross human rights abuses – such