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Easy come, easy go: Venezuela removals

Along with the removal of Venezuela General License 37, today, OFAC removed the following entities and vessels from the SDN List: SEAHERO Crude Oil Tanker Bahamas flag; Vessel Registration Identification IMO 9315642 (vessel) [VENEZUELA-EO13850] (Linked To: ADAMANT MARITIME LTD). ADAMANT MARITIME LTD, Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro, […]

OFAC adds some, removes some Venezuela designations, issues a General License & an FAQ

Earlier today, OFAC added the following persons: ESPARZA GARCIA, Veronica, Mexico; DOB 16 Jan 1973; POB Sinaloa, Mexico; citizen Mexico; Gender Female; C.U.R.P. EAGV730116MSLSRR04 (Mexico) (individual) [VENEZUELA-EO13850]. LEAL JIMENEZ, Joaquin, Mexico; DOB 17 Jul 1992; POB Guanajuato, Mexico; citizen Mexico; Gender Male; C.U.R.P. LEJJ920717HGTLMQ01 (Mexico) (individual) [VENEZUELA-EO13850]. ZEPEDA ESPARZA, Olga […]

What about a SHTA for North Korea?

That’s the subject of my new article for Regulation Asia – Humanitarian Trade with North Korea: A Matter of Trust. It’s not just finding a government that will provide a clearinghouse for the transactions and the associated due diligence and reporting – it’s navigating the geopolitics, too. Let me know […]

May 21, 2020: We’ve got new ZSRs!

Publication of Amended Zimbabwe Sanctions Regulations 5/21/2020 The Office of Foreign Assets Control (OFAC) is amending the Zimbabwe Sanctions Regulations, 31 C.F.R. part 541.  This regulatory amendment is currently available for public inspection with the Federal Register and will take effect upon publication in the Federal Register on May 22, 2020. […]

50 Percent Rule? Not for Nynas…

Removal of Venezuela-related General License 13E, Issuance of Venezuela-related General Licenses 3H and 9G, and Amended Frequently Asked Questions 5/12/2020 The Department of the Treasury’s Office of Foreign Assets Control (OFAC) is revoking and archiving on its website Venezuela-related General License (GL) 13E “Authorizing Certain Activities Involving Nynas AB,” and […]

Sanctions in the age of pandemic…

See my new article Are Sanctions Cruel? over at KYC360 – it’s about the current brouhaha over relaxing sanctions because sanctioned countries are apparently having difficulties receiving aid – and the available humanitarian mechanisms provided under US sanctions regulations. Hint: it’s more complicated than that.

OFAC Humanitarian Aid Fact Sheet: Other Guidance Resources

Other Cross-Programmatic Guidance • “OFAC Licensing Process” – Provides guidance on the OFAC licensing process. • “Guidance Related to the Provision of Humanitarian Assistance by Not-For-Profit Non- Governmental Organizations” – Clarifies the reach of economic sanctions for the non- governmental organizations involved in the provision of humanitarian assistance. (October 2014)