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Last week's major developments in sanctions - November 21st to November 26th, 2022

Updated: Dec 13, 2022

Monday, November 21

  • OFAC issued General License No.13C "Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024." The general license authorizes the U.S. persons to pay taxes, fees, or import duties, and purchase or receive permits, licenses, registrations, or certifications Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation, provided such transactions are ordinarily incident and necessary to the day-to-day operations in the Russian Federation of such U.S. persons or entities, through March 7, 2023.

Tuesday, November 22

  • As the date for the implementation of the Russian origin oil price cap approaches, OFAC took the following steps:

    1. Published a determination "Prohibitions on Certain Services as They Relate to the Maritime Transport of Crude Oil of Russian Federation Origin;"

    2. Published Guidance on Implementation of the Price Cap Policy for Crude Oil of Russian Federation Origin; and

    3. Issued three general licenses General License 55 (authorizing transactions related to the maritime transport of crude oil originating from the Sakhalin-2 project through September 30, 2023) General License 56 (authorizing transactions related to the importation of crude oil into the Republic of Bulgaria, the Republic of Croatia, or landlocked European Union Member States as described in Council Regulation (EU) 2022/879 of June 3, 2022), and General License 57 (authorizing transactions that are ordinarily incident and necessary to addressing vessel emergencies related to the health or safety of the crew or environmental protection, including safe docking or anchoring, emergency repairs, or salvage operations) to minimize the unintended effects of the new restrictions on the Russian origin oil.

  • OFSI published an updated version of its "Transportation Sanction" guidance to reflect the restrictions imposed on Russia and Belarus. (Here)

Wednesday, November 23

Thursday, November 24

  • No major development on this day. (It was Thanksgiving day in the U.S.)

Friday, November 25

  • No major development on this day. (It was a public holiday in the U.S.)

Saturday, November 26

  • Over the weekend OFAC took the following actions upon the resumption of Mexico City Talks between the Unitary Platform, a Venezuelan opposition political alliance, and the Maduro regime: (relevant press release)

    1. Replaced General License 8J with 8K, authorizing transactions involving Petróleos de Venezuela, S.A. necessary for the limited maintenance of essential operations in Venezuela or the wind down of operations in Venezuela for certain entities;

    2. Issued General License 41 under Venezuela Sanctions Regulations authorizing certain transactions related to Chevron Corporation’s joint ventures in Venezuela; and

    3. Published two new FAQs (FAQs 1098 and 1099).

Recommendation of the Week

  • This week, I would like to recommend a report on the use of global targeted human rights and corruption sanctions programs in the United States, Canada, the United Kingdom, and the European Union since 2017 that has been prepared by four NGOs: Human Rights First, Open Society Foundations, Raoul Wallenberg Centre for Human Rights and REDRESS (Report: Multilateral Magnitsky Sanctions at Five Years)


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