US Department of Commerce Further Tightens Cuba Sanctions

On October 18, 2019, the Bureau of Industry and Security (BIS) of the US Department of Commerce announced that it will further restrict the Cuban regime's access to goods, including commercial aircraft. This action is in response to Cuba's domestic situation, as well as its support of the Maduro regime in Venezuela.

The expanded sanctions revoke the existing license for aircraft leases to Cuban state-owned airlines, amend the licensing policy with the establishment of a denial for leases of aircraft to Cuban state-owned airlines, and clarify that aircraft and vessels are not eligible for the License Exception Aircraft and Vessels (AVS) if they are leased to or chartered by a national of Cuba. Additionally, the sanctions establish a general 10% de minimis level of US-origin content for Cuba, revise License Exception Support for the Cuban People (SCP) to render the Cuban government and Communist Party ineligible for donations of items for use in scientific, archeological, cultural, ecological, educational, historic preservation or sporting activities, and remove authorization for promotional items that benefit the Cuban government. Finally, the revision clarifies the scope of telecommunication items, limited only to infrastructure to improve the freedom of information that the Cuban government is able to receive without a license.

US Department of Commerce Adds 28 Chinese Organizations to Its Entity List

In response to ongoing human rights violations, BIS announced that it would add 28 Chinese governmental and commercial organizations to the Entity List for engaging in or enabling activities contrary to the foreign policy interests of the US. This action targets those entities implicated in human rights violations and abuses in China's campaign targeting Uighurs and other predominantly Muslim ethnic minorities in the Xinjiang Uighur Autonomous Region (XUAR). The additions include the XUAR People's Government Public Security Bureau, 19 subordinate elements and eight commercial entities.

Office of Foreign Assets Control (OFAC) Issues Amended Venezuela-related General Licenses 8D and 13D

Recently, the Department of the Treasury's OFAC issued an amended General License 8D, "Authorizing Transactions Involving Petróleos de Venezuela, S.A. (PdVSA) Necessary for Maintenance of Operations for Certain Entities in Venezuela." General License 8D replaces General License No. 8C and authorizes transactions not related to the exportation of reexportation of diluents and not otherwise prohibited with PdVSA by Chevron Corporation, Halliburton, Schlumberger Limited, Baker Hughes, Weatherford International and their subsidiaries through January 22, 2020. OFAC also issued an amended General License 13D, "Authorizing Certain Activities Involving Nynas AB." General License 13D replaces General License 13C and authorizes transactions not related to the exportation of reexportation of diluents or the purchase or acquisition of Venezuelan-origin petroleum or petroleum products, and not otherwise prohibited with Nynas AB and any of its subsidiaries through April 14, 2020.

OFAC Temporarily Extends Belarus-related General License

On October 22, 2019, OFAC issued General License No. 2G – General License with Respect to Entities Blocked Pursuant to Executive Order 13405, extending the expiration date of the general license to April 26, 2021. General License No. 2G replaces General License No. 2F and authorizes transactions with blocked entities by Belerusian Oil Trade House, Belneftekhim, Belneftekhim USA, Inc., Belshina OAO, Godno Azot OAO, Gordno Khimvolokno OAO, Lakokraska OAO, Naftan OAO, Polotsk Steklovolokno OAO and their subsidiaries. Additionally, General License No. 2G includes a reporting requirement for any transaction or series of transactions in excess of US$50,000.

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