USA: latest updates on international sanctions

We report an update of recent U.S. policy and legislative actions against legal entities or subjects, countries (Venezuela, Yemen, Libya, Zimbabwe, Bosnia and Herzegovina, Nicaragua, Iran, Democratic People’s Republic of Korea, Russia) and specific commodities.

Non-U.S. entities

On March 14, 2024, a private global banking group headquartered in Switzerland with about 40 branches worldwide was sanctioned by the United States for $3,740,442 for violating several U.S. sanctions programs. The banking group, in fact, caused U.S. securities firms to process several securities-related transactions on behalf of entities in Cuba, approved financial transactions related to an entity listed within the Kingpin Act individual, and in 2023 issued dividend payments for securities held in the U.S. of an entity listed by Executive Order 14024 related to Russia.

Venezuela

In October 2023, the Office for Foreign Assest Control (OFAC) approved General License No. 44 “Authorizing Transaction Related to Oil or Gas Sector Operations in Venezuela,” through which various activities otherwise prohibited under Executive Order 13884 could be authorized. The validity of this authorization will extend until April 18, 2024. Specifically, the production, extraction, sale, and export of oil and gas from Venezuela, as well as the provision of related services, payment of invoices for goods or services related to the oil and gas sector in Venezuela, new investments in oil and gas operations, and finally the delivery of oil and gas from Venezuela to creditors of the Government of Venezuela for the purpose of debt relief are authorized.

On Jan. 29, 2024, OFAC published General License 43A, which supersedes and repeals General License 43; while the latter authorized certain transactions with the Venezuelan entity CGV Compania General di Mineria de Venezuela VA, the new General License 43A anticipates all previously permitted benefits to lapse on February 13, 2024.

Yemen

The designation of the Houthis within the Specially Designated Global Terrorist (SDGT) under Executive Order 13224 went into effect on Feb. 16, 2024. This had been officially announced by the U.S. Department of State last Jan. 17, due to the unprecedented attacks committed against international maritime vessels in the Red Sea and Gulf of Aden, as well as against military forces positioned in the area to defend the safety and security of commercial shipping, which endangered seafarers, disrupted the free flow of commerce, and interfered with navigational rights and freedoms.