In his State of the Union address to Congress last night, President Donald Trump spoke of the “great American comeback” and claimed that “[t]he years of economic decay are over.  The days of our country being used, taken advantage of, and even scorned by other nations are long behind us.” His prepared speech focused briefly

The Department of Commerce’s Bureau of Industry and Security (BIS) further tightened U.S. sanctions on Cuba “for its repression of the Cuban people and its support of the Maduro regime in Venezuela.” Overall, the United States maintains a comprehensive embargo on trade with Cuba, and the export and reexport to Cuba of items subject to

In September, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) continued to tighten its sanctions on Iran and Venezuela, and addressed a sanctions-evading scheme for Syria involving several Russian entities.

  • Iran: On September 20, 2019, OFAC announced that it was designating the Central Bank of Iran (CBI), the National Development

The Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that, effective October 9, 2019, the Cuban Assets Control Regulations (CACR) will be amended to further restrict certain financial transactions involving Cuba and to deny Cuba access to hard currency. In a press release, OFAC announced that these changes will amend certain

President Trump yesterday signed an executive order imposing additional sanctions on the Venezuelan government. The order, “Blocking Property of the Government of Venezuela,” blocks all property and interests in property of the Venezuelan government within the jurisdiction of the United States. It authorizes the secretary of Treasury, in consultation with the secretary of State, to

During the month of May while President Donald Trump’s escalating trade war with China was garnering most of the headlines, the Trump administration also continued to apply economic pressure on Venezuela. In May, the Departments of Commerce, State and the Treasury further tightened sanctions and export restrictions on Venezuela.

On May 10, 2019, the Department of State announced that, pursuant to Executive Order 13850, the United States determined persons operating in the defense and security sector of the Venezuelan economy may be subject to economic sanctions. On the same date, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned two companies that operate in the oil sector of the Venezuelan economy, and also sanctioned two vessels, which transported oil from Venezuela to Cuba:

  • Monsoon Navigation Corporation is based in Majuro, Marshall Islands, and is the registered owner of the vessel, Ocean Elegance.
    • Ocean Elegance is a crude oil tanker (IMO: 9038749) that delivered crude oil from Venezuela to Cuba from late 2018 through March 2019.
  • Serenity Maritime Limited is based in Monrovia, Liberia, and is the registered owner of the vessel, Leon Dias.
    • Leon Dias is a chemical and oil tanker (IMO: 9396385) that delivered crude oil from Venezuela to Cuba from late 2018 through March 2019.

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In a series of actions on April 17, the Trump administration announced the implementation of additional sanctions on the “Troika of Tyranny” in the Western Hemisphere (see Trump and Trade Update of November 16, 2018). President Donald J. Trump and his National Security Advisor John Bolton have long held that Cuba, Venezuela and Nicaragua

On Friday, January 25, 2019, President Trump issued a new Executive Order expanding the current sanctions imposed on the government of Venezuela to target the country’s state-owned oil company Petróleos de Venezuela, S.A. (PdVSA) – its primary source of revenue – and to increase pressure on Venezuelan President Nicolas Maduro to step down. This followed the Trump administration’s announcement on January 23, 2019 to formally recognize Juan Guaidó as the interim president of Venezuela and declare Maduro to be illegitimate. In response to the order, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) on January 28, 2019 placed PdVSA on the Specially Designated Nationals (SDN) List and issued General Licenses that will continue for a specified period of time to authorize certain transactions and activities related to PdVSA and its subsidiaries.

Companies or individuals holding debt with certain entities directly or indirectly affiliated with PdVSA must ensure they are fully aware of these recent developments. Due to these modifications, existing contracts and open obligations should be reviewed to ensure they continue to be structured within the scope of these new General Licenses, and, given this heightened political situation, companies should be prepared for additional actions taken by the Trump administration in the form of additional sanctions or other targeted prohibitions until the Maduro regime is replaced.
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