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  • OFAC updates Iran, Venezuela FAQs

    Financial Crimes

    On September 30, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced the publication of a new Iran-related FAQ. FAQ 932 clarifies that “transactions ordinarily incident to travel to or from Iran by U.S. persons are within an exemption under the Iranian Transactions and Sanctions Regulations (ITSR), 31 C.F.R. part 560, and therefore generally are not prohibited.” OFAC also noted that U.S. persons could be prohibited from engaging in transactions associated with persons blocked by sanctions programs or authorities outside the scope of the ITSR.

    The same week, on October 1, OFAC announced the publication of a new Venezuela-related FAQ. FAQ 933 clarifies that authorizations in paragraph (a) of Venezuela-related General Licenses 7C and 20B, respectively, have not expired.

    Financial Crimes OFAC Department of Treasury OFAC Designations OFAC Sanctions Of Interest to Non-US Persons Venezuela Iran

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  • OFAC issues amended Venezuela-related general license and FAQ

    Financial Crimes

    On September 10, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued Venezuela General License (GL) 5H, which supersedes GL 5G and authorizes certain transactions otherwise prohibited under Executive Orders 13835 and 13857 related to, or that provide financing for, dealings in the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or after January 22, 2022. Concurrently, OFAC amended a Venezuela-related frequently asked question regarding GL 5H.

    Financial Crimes OFAC Department of Treasury OFAC Sanctions Of Interest to Non-US Persons Venezuela

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  • OFAC issues new general license and related FAQs involving Venezuela

    Financial Crimes

    On July 12, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued General License (GL) 40, “Authorizing Certain Transactions Involving the Exportation or Reexportation of Liquefied Petroleum Gas to Venezuela.” GL 40 permits transactions and activities otherwise prohibited by Executive Order 13884 (covered by InfoBytes here) involving “the Government of Venezuela, Petróleos de Venezuela, S.A. (PdVSA), or any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest.” OFAC also published two new FAQs, 914 and 915, related to GL 40.

    Financial Crimes OFAC Of Interest to Non-US Persons Department of Treasury OFAC Sanctions FAQs Venezuela

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  • OFAC issues Covid-19 related general license and FAQs

    Financial Crimes

    On June 17, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued three general licenses, Iran GL N, Syria GL 21, and Venezuela GL 39, (referred to as the “COVID-19-related GLs”) to expand upon Treasury’s existing authorizations for Covid-19-related transactions and activities. As previously covered by InfoBytes, OFAC published a Fact Sheet providing guidance to ensure humanitarian-related trade and assistance reaches at-risk populations through legitimate and transparent channels during the global Covid-19 pandemic. The recently released COVID-19-related GLs build on longstanding humanitarian exemptions, exceptions, and authorizations to cover Covid-19-related transactions and activities, which include, among others, “transactions and activities involving the delivery of face masks, ventilators and oxygen tanks, vaccines and the production of vaccines, COVID-19 tests, air filtration systems, and COVID-19-related field hospitals.” These GLs are also part of the Biden Administration’s efforts designated in National Security Memorandum – 1, which directs certain government agencies to review existing U.S. and “multilateral financial and economic sanctions to evaluate whether they are unduly hindering responses to the COVID-19 pandemic worldwide.” According to OFAC, these new authorizations will continue to support the effort by governments, international organizations, non-governmental organizations, and private sector actors in providing Covid-19-related assistance to people in certain sanctioned jurisdictions. OFAC also published six FAQs related to the COVID-19-related GLs (see 906, 907, 908, 909, 910, and 911).

    Financial Crimes OFAC Sanctions Of Interest to Non-US Persons Department of Treasury Covid-19 Iran Syria Venezuela

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  • OFAC amends Venezuela-related general license

    Financial Crimes

    On June 1, the U.S. Treasury Department’s Office of Foreign Assets Control issued Venezuela-related General License (GL) 8H, which authorizes transactions involving Petróleos de Venezuela, S.A. (PdVSA) necessary for the limited maintenance of essential operations in Venezuela or the wind down of operations in Venezuela for certain entities that would otherwise be prohibited by Executive Order 13850, as incorporated into the Venezuela Sanctions Regulations. (Covered by InfoBytes here.) Effective June 1, GL 8H replaces GL 8G, which was issued November 2020.

    Financial Crimes Venezuela OFAC Department of Treasury Sanctions OFAC Designations Of Interest to Non-US Persons

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  • OFAC amends Venezuela-related general license

    Financial Crimes

    On February 2, the U.S. Treasury Department’s Office of Foreign Assets Control issued Venezuela-related General License (GL) 30A, which authorizes certain necessary to port and airport operations that would otherwise be prohibited by Executive Order (E.O.) 13884, as incorporated into the Venezuela Sanctions Regulations. (See previous InfoBytes coverage here.) Effective February 2, G.L. 30A replaces G.L. 30, which was issued in August of 2019.

    Financial Crimes OFAC OFAC Designations Of Interest to Non-US Persons Department of Treasury Venezuela Sanctions

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  • OFAC targets Venezuelan oil sector sanctions evasion network

    Financial Crimes

    On January 19, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13850 against three individuals, fourteen entities, and six vessels for allegedly engaging in activities tied to a Mexico-based network involved in the illicit sale of hundreds of millions of dollars of Venezuelan oil. The action builds on OFAC’s June 2020 sanctions against three individuals and eight foreign entities for allegedly engaging in activities in or associated with a network attempting to evade U.S. sanctions on Venezuela’s oil sector in order to benefit “the illegitimate Maduro regime” and Venezuela’s state-owned oil company, Petroleos de Venezuela, S.A. (covered by InfoBytes here). As a result, all property and interests in property belonging to the identified individuals and entities subject to U.S. jurisdiction are blocked, and “any entities that are owned, directly or indirectly, 50 percent or more by the designated entities, are also blocked.” U.S. persons are generally prohibited from dealing with any property or interests in property of blocked or designated persons.

    Financial Crimes OFAC Department of Treasury Venezuela Sanctions Of Interest to Non-US Persons OFAC Designations

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  • OFAC issues counter terrorism general licenses and related FAQs, updates SDN List

    Financial Crimes

    On January 19, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued four General Licenses in conjunction with State Department designations against a foreign terrorist organization: General License 9, “Official Business of the United States Government,” General License 10, “Official Activities of Certain International Organizations,” General License 11, “Certain Transactions in Support of Nongovernmental Organizations’ Activities in Yemen,” and General License 12, “Transactions Related to the Exportation or Reexportation of Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components or Software Updates.” The general licenses authorize certain transactions ordinarily prohibited by the Global Terrorism Sanctions Regulations, Foreign Terrorist Organizations Sanctions Regulations, and Executive Order 13224, including actions “to help facilitate the uninterrupted flow of humanitarian assistance, including COVID-19-related assistance, and certain other critical commodities to the people of Yemen that would otherwise be prohibited pursuant to authorities administered by OFAC.” OFAC also published related FAQs 875, 876, and 877.

    OFAC also updated its Specially Designated Nationals and Blocked Persons List to add individuals and entities associated with Venezuela, Russia, and Yemen designations.

    Financial Crimes OFAC Department of Treasury Yemen Russia Venezuela Sanctions Of Interest to Non-US Persons OFAC Designations

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  • OFAC issues amended Venezuela-related general license, sanctions Venezuelan officials

    Financial Crimes

    On January 4, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License (GL) 31A and an amended related frequently asked question. GL 31A authorizes certain transactions and activities involving the IV Venezuelan National Assembly, the Interim President of Venezuela, and certain other persons that would otherwise be prohibited by Executive Order (E.O.) 13884, as incorporated into the Venezuela Sanctions Regulations. (See previous InfoBytes coverage here.)

    Additionally, earlier on December 30, OFAC announced sanctions pursuant to E.O. 13692 against two Venezuelan government officials who presided over the trials of six U.S. persons in Venezuela. According to OFAC, the six executives’ trials “were based on politically motivated charges and marred by a lack of fair trial guarantees.” As a result, all property and interests in property belonging to the identified individuals subject to U.S. jurisdiction are blocked, and “any entities that are owned, directly or indirectly, 50 percent or more by the designated persons are also blocked.” U.S. persons are generally prohibited from engaging in any dealings involving the property or interests in property of blocked or designated persons.

    Financial Crimes OFAC Department of Treasury Venezuela Sanctions Of Interest to Non-US Persons OFAC Designations

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  • OFAC amends Venezuela and Ukraine-related general licenses

    Financial Crimes

    On December 23, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued General License (GL) 5F, “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After July 21, 2021,” which replaces and supersedes GL 5E. OFAC also amended related FAQ 595, which reminds parties that, until July 21, 2021, transactions related to the sale or transfer of CITGO shares in connection with the PdVSA 2020 8.5 percent bond are prohibited, unless specifically authorized by OFAC.

    Additionally, OFAC concurrently announced the issuance of Ukraine-related GLs 13P and 15J. GL 13P, “Authorizing Certain Transactions Necessary to Divest or Transfer Debt, Equity, or Other Holdings in GAZ Group,” is effective December 23 and replaces and supersedes GL 13O. Additionally, GL 15J, “Authorizing Certain Activities Involving GAZ Group,” is also effective on December 23 and replaces and supersedes GL 15I.

    Financial Crimes OFAC Venezuela Ukraine Of Interest to Non-US Persons Sanctions

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