The Treasury Department this week released its first-ever “de-risking strategy,” a set of findings and policy recommendations to address issues arising from banks that cut off business relationships with “broad categories of customers” rather than taking steps to analyze and manage those relationships. The report, mandated by the Anti-Money Laundering Act of 2020, said profits are the “primary factor” in financial institutions’ decisions to de-risk, including the sometimes high cost and challenging prospect of implementing a sanctions compliance program.
The Office of Foreign Assets Control this week published previously issued Syrian Sanctions Regulations General License 22. The notice includes the full text of the license.
House lawmakers are working on legislation they say could lift some of the International Traffic in Arms Regulations’ burdensome technology sharing restrictions, including controls limiting trade with the U.S.’ closest allies. Rep. Michael McCaul, R-Tex., said the bill could create an ITAR exemption for technology transfers under the Australia-U.K.-U.S. (AUKUS) partnership, among other changes.
The Office of Foreign Assets Control April 19 again extended a general license that continues to delay an exemption that would authorize certain transactions related to Petroleos de Venezuela, S.A. General License 5K, which replaced GL 5J, now authorizes certain transactions with PdVSA involving an 8.5% bond on or after July 20. The agency also updated a frequently asked question to reflect the change. The previous license was set to allow those transactions to occur on or after April 20.
The U.K. issued a General License under its Russia sanctions regime allowing Russian Railways to pay Lithuanian Railways for the rail transit of individuals between the Kaliningrad region and other parts of Russia. The license "excludes the transit of goods." The license expires April 13, 2025.
The U.K. updated its industry guidance on its Russia maritime services ban and oil price cap, noting the cap will stay under review and will be updated subject to the agreement of the Oil Price Cap Coalition. It also explains that, for the maritime services ban, a person supplying or delivering goods by ship includes a person who owns, controls, charters or operates a ship on which those goods are being carried from or to which those goods are being transferred, the EU Sanctions blog said April 12.
The U.S. this week announced new Russia-related trade restrictions, adding 28 entities to the Commerce Department’s Entity List and more than 100 entries to the Treasury Department’s Specially Designated Nationals List. The measures target people and companies either operating in Russia, aiding the country’s war against Ukraine or helping Moscow evade sanctions.
The U.K.'s Office of Financial Sanctions Implementation renewed until Oct. 28 its legal services General License under the Russia sanctions regime (see 2210310020), the EU Sanctions blog reported this week. The renewed license, which was set to expire April 28, will again cap legal fees at $621,000, including value-added taxes, and will cap legal expenses at 5% of legal fees up to $31,000. The renewed license, which the blog said was outlined in a recent "letter to stakeholders" from the government, also clarifies that it is applicable in certain cases in which the "fees and / or expenses may exceed the legal fees and / or expenses caps." The license will not authorize legal fees for "defamation and similar cases," the blog said.
The Office of Foreign Assets Control this week published three previously issued general licenses under its Libyan Sanctions Regulations. The notice includes the full text of each license.
The upcoming expiration of the Bureau of Industry and Security's temporary general license outlined in the China-related chip controls from October presents “good opportunities to see” how the agency will “interpret and enforce the new restrictions,” Lee, Tsai & Partners said in a recent client alert. The TGL expires April 7, when BIS has said it will begin reviewing license applications for activities that were covered by the TGL on a case-by-case basis (see 2301270026).