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After Venezuela’s government and its political opposition agreed on electoral guarantees for 2024 presidential elections, the Office of Foreign Assets Control (OFAC) issued four general licenses suspending select sanctions:

  • General License 44 temporarily authorizes all transactions related to Venezuelan oil and gas sector operations, including producing, lifting, selling, and exporting oil or gas from Venezuela and new investment in oil or gas sector operations. The authorization includes transactions involving Petróleos de Venezuela, S.A. (PdVSA) or any entity in which PdVSA directly or indirectly owns a 50% or greater interest.

    The license expires on April 18, 2024. OFAC will only renew the license if Maduro’s government follows through with its commitments and continues taking measurable steps toward democratic elections in 2024.

  • General License 43 authorizes transactions involving CVG Compania General de Mineria de Venezuela CA (known as Minerven), the state-owned gold mining company.
  • General License 3I and General License 9H remove the secondary market trading bans on buying certain Venezuelan sovereign bonds, as well as pre-2017 PdVSA bonds or equity.

Continue Reading Overview: U.S. eases Venezuela-related sanctions after election deal

As a follow-on to last week’s quint-seal guidance, the Bureau of Industry and Security (BIS) published best practice guidance to help prevent high-priority items from being diverted to Russia. The latest guidance focuses on exports of the following high-priority items to counterparties in countries outside the Global Export Controls Coalition (GECC):[1]

HS Code
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On Tuesday, the U.S., UK, Australia, Canada, and New Zealand—known as the “Export Enforcement Five” or “E5”—issued joint guidance to industry and academia on how best to identify Russian export control evasion tactics. The E5 coordinates with other members of the Global Export Control Coalition (GECC) on export controls specific to Russia. In addition to…

On August 9, 2023, President Biden issued his much anticipated executive order on outbound U.S. investment in China, Hong Kong, and Macau (dubbed “reverse CFIUS”). The Treasury Department simultaneously released an advance notice of proposed rulemaking (ANPRM) related to the order. Public comments on the ANPRM will be accepted until September 28. The final rule…

In October, the Bureau of Industry and Security (BIS) strengthened its antiboycott enforcement strategy. Last week, BIS made two additional enhancements to its enforcement strategy:

  • New Boycott Request Reporting Form. U.S. persons who receive boycott requests will now be required to identify the requesting party in addition to the country from which the
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The U.S. Department of Justice (DOJ), Bureau of Industry and Security (BIS), and Office of Foreign Assets Control (OFAC) published their second Tri-Seal Compliance Note on July 26 summarizing their voluntary self-disclosure procedures for export control and sanctions violations. The Note highlights the potential benefits of self-disclosure, including significant mitigation of civil and criminal liability.…

U.S. Customs and Border Protection’s (CBP) statistics confirm that the Uyghur Forced Labor Prevention Act’s (UFLPA) reach extends beyond imports from China. Though importers must remain focused on mitigating UFLPA compliance risks for Chinese-origin goods, CBP’s enforcement statistics offer a broader perspective on the scope of UFLPA-related detentions and seizures.

We highlight key takeaways and…

In coordination with the G7 and other international partners, the U.S. implemented new Russia-related sanctions and export controls on May 19, 2023. The U.S. also released an additional select list of potential export control evasion “red flags.”

Restrictive economic measures

The Office of Foreign Assets Control (OFAC):

  • Sanctioned 22 individuals and 104 entities in more
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The Civil Rights Division of the Department of Justice has issued guidance clarifying that when a position requires access to export-controlled information or items, that requirement is not a basis for making an employment decision based on citizenship, immigration status, or national origin.

In our recent alert on reedsmith.com, we examine U.S. export control…

The Bureau of Industry and Security (BIS) has clarified two enforcement policies in an attempt to incentivize voluntary self-disclosures and disclosures about others’ possible violations of the Export Administration Regulations (EAR).

In our recent post, we consider the implications of this latest development.