• Deanna Clark-Esposito

OFAC Updates Week 1/4/21



January 4, 2021

The Office of Foreign Assets Control (OFAC) has announced issued Venezuela-related General License 31A, "Certain Transactions Involving the IV Venezuelan National Assembly, the Interim President of Venezuela, and Certain Other Persons Authorized". In response to this new license, OFAC has also amended their Frequently Asked Questions (FAQs) to include FAQ 679.


OFAC has announced a settlement with Union de Banques Arabes et Françaises (UBAF) of $8,572,500 for 127 apparent violations of Syria-related sanctions. UBAF is a France based bank that facilitates trade finance between Europe and the Middle East, North Africa, sub-Saharan Africa and Asia. UBAF processed payments on the behalf of sanctioned Syrian financial institutes.


OFAC has published a new FAQ related to Executive Order 13959, "Addressing the Threat from Securities Investments that Finance Communist Chinese Military Companies." The question is related to the whether U.S. entities need to divest holdings in publicly traded securities of Communist Chinese Military Companies as identified in the Executive Order.


January 5, 2021

OFAC has updated its Specially Designated Nationals and Blocked Persons (SDN) List with Iran-related designations. The designations were placed upon a variety of Iranian steel and mining corporations and a single shipping company.


January 6, 2021

OFAC has published two additional FAQs about Communist Chinese Military Companies in response to Executive Order 13959. FAQ 863 answers whether U.S. persons may custody, offer for sale, serve as a transfer agent or trade in covered securities with Chinese Military Companies. FAQ 864 answers whether the Executive Order applies to transactions in securities of a company subsidiary with a name that exactly or closely matches that of an entity identified as blocked by the Executive Order.

OFAC has published FAQ 865 to further clarify regulations set in place by Executive Order 13959 regarding Communist Chinese Military Companies. The FAQ addresses whether market intermediaries and other participants facilitate divestment from publicly traded securities of Communist Chinese Military Companies.


January 8, 2021

OFAC has updated its Non-SDN Communist Chinese Military Companies List. Additionally, OFAC has added a Global Magnitsky (GLOMAG) entry to the SDN List. The GLOMAG entry was a single Iraqi individual.

OFAC has issued the Communist Chinese Military Companies General License 1, "Authorizing Transactions Involving Securities of Certain Communist Chinese Military Companies." The license offers general guidance for interacting with Communist Chinese Military Companies identified by Executive Order 13969 but that have not been listed on OFAC's Non-SDN Communist Chinese Military Companies List.


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