The Congressional Research Service this week updated its report on U.S. sanctions against Venezuela, outlining the types of designations imposed on the country and policy considerations for the U.S. government and Congress. The report now reflects the Treasury Department’s decision last month to grant Chevron a general license to resume certain oil activities in Venezuela for the first time in years (see 2211280042). CRS said “fluctuations in oil prices also have put pressure on U.S. and European officials to find alternate sources to replace Russian-supplied oil.”
The maritime industry should see an increase in Russian sanctions evasion tactics as the U.S., the EU and others prepare to set a price cap on Russian oil, said David Tannenbaum, a former sanctions compliance specialist at the Office of Foreign Assets Control. Logistics companies and others should be on the lookout for a rise in deceptive maritime practices, which could call for more compliance work and recordkeeping to avoid running afoul of U.S. sanctions, said Marco Crusafio, an international shipping lawyer with Squire Patton.
The U.S. will allow Chevron to resume certain oil activities in Venezuela, giving the California-based energy company a “limited” license to pump oil in the sanctioned country for the first time in years. The license, which the White House believes will have a minimal impact on Venezuela's oil shipments, was issued in an effort to support the newly restarted negotiations between President Nicolas Maduro’s regime and the country’s opposition party, the Treasury Department said. It also comes amid opposition from U.S. Republicans, who warned the administration that a license would only offer the Maduro regime sanctions relief and undermine prospects for the return of democracy to Venezuela (see 2211020032, 2210280032 and 2210060014).
The Office of Foreign Assets Control this week issued a determination that will prohibit certain shipping services related to Russian oil, and said it will soon announce a price cap on Russian fuel alongside its G-7 partners. The agency also issued a guidance outlining how it plans to implement the price cap -- including compliance requirements for U.S. service providers -- and three related general licenses.
The Office of Foreign Assets Control on Nov. 21 extended a Russia-related general license that authorizes the payment of certain taxes and import fees to the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation or the Ministry of Finance of the Russian Federation despite the sanctions imposed on those entities. General License 13C, which replaces GL 13B (see 2209080047), extends the authorization through 12:01 a.m. EST on March 7, 2023. GL13B was scheduled to expire Dec. 7.
The U.K.'s Office of Financial Sanctions Implementation on Nov. 17 issued a new general license that authorizes certain payments to energy companies for gas or electricity. The payments can be made to Office of Gas and Electricity Markets (OFGEM)-registered energy companies from a frozen U.K. bank account via transfer or direct debit. The OFGEM-registered companies can receive the payments and make return payments to frozen bank accounts, the license said. Designated parties can also receive return payments from energy companies into a frozen U.K. bank account. The license permits this activity through April 16, 2023.
The Nuclear Regulatory Commission last week published a final rule that made various corrections to its regulations, including the restoration of a general export license that it had “incorrectly” removed in 2010. The general license allows exports of uranium from the U.S. “enriched to less than 20 percent in U-235, in the form of UF6 heels in cylinders being returned to suppliers” in member countries of the European Atomic Energy Community or the U.K., DLA Piper said in a client alert. The law firm noted that other forms of uranium materials and related technology are controlled by the Commerce Department’s Export Administration Regulations or the State Department’s International Traffic in Arms Regulations. The NRC’s rule takes effect Dec 14.
The Office of Foreign Assets Control in a Nov. 18 notice issued Russia-related General License 54 authorizing all transactions necessary for the purchase or receipt of any debt or equity securities of VEON Ltd, a multinational telecommunication services company. The license authorizes transactions that would otherwise be prohibited by executive order 14071, Prohibiting New Investment in and Certain Services to the Russian Federation, provided that the debt or equity securities were issued prior to June 6. The license does not authorize transactions otherwise prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, including transactions involving any blocked person, unless separately authorized.
The G-20 this week said countries should avoid introducing food export restrictions that are inconsistent with World Trade Organization rules and stressed the importance of keeping food supply chains running. In a joint statement after their meetings in Indonesia, leaders of the G-20 nations said they are committed to keeping food supply chains “functioning under challenging circumstances.”
The U.K.'s Office of Financial Sanctions Implementation on Nov. 14 released a blog post and guidance on the Russian oil price cap. The post coincides with the introduction of the maritime services ban and the price cap exception for crude oil. OFSI said that a General License creating the price cap will be released before Dec. 5 and that additional licenses to "ensure international alignment and the smooth operation of the Price Cap will also be published" before Dec. 5.