Each quarter, we send many of our clients a quarterly trade compliance update, highlighting important developments over the last few months and summarizing key points for important sanctions programs.

Click here to download the quarterly update for April.

Below is a summary of events this past quarter:

• OFAC continues to roll back Venezuelan sanctions relief.  General License 44A creates a wind down period for transactions with PdVSA until May 31, 2024. Restrictions may continue to change in the coming months depending on Venezuela’s actions.
• E.O. 14115 – Imposing Sanctions on Persons Undermining Peace, Security, and Stability in the West Bank – designates individuals in Palestine.  Additional designations made under other sanctions programs, expect this trend to continue for the foreseeable future. 
• Continued expansion of sanctions and export controls relating to Russia and Belarus. New regulations target shipping, industrial, diamond, metal, and defense sectors in these countries. OFAC fully designated state-owned JSC Sovcomflot. OFAC and western allies continue to enforce the Russia crude oil price cap and published a Price Cap Coalition Compliance and Enforcement Alert.
• Issuance of Tri-Seal Compliance Note – Obligations of Foreign-Based Persons to Comply with U.S. Sanctions and Export Control Laws. 

About the document:

This handy one-pager is designed to be used by our clients to provide a quick reference guide for the complex topics of trade sanctions and export control regulations. The goal is to briefly summarize key points for each program.

This document can be especially useful for non-lawyers and non-compliance officers. Some of our clients distribute the document to the sales and operations teams, or hang it with other legal and compliance material somewhere in the office. Many front-line employees need to know enough about sanctions to identify red flags and then engage legal and compliance as needed. We’ve unfortunately seen unwitting violations due to a lack of education or a lack of reference materials.

If you would like to be on the distribution list going forward, please email Matt Stankiewicz at [email protected]. And if you have any further questions, please reach out!