China’s new export control law (see 2010190033 and 2010220024) is expected to significantly impact trade and may include “very broad” catch-all controls, leading to compliance burdens for companies doing business in China, law firms said. Businesses should review their compliance programs to make sure they are prepared for the regulations and to avoid potential Chinese penalties, firms said, which could be severe.
The Office of Foreign Assets Control on Oct. 29 issued an Iran-related general license related to exports of “educational services” and released a new frequently asked question. General License M authorizes U.S. “academic institutions” to export “additional services” to Iranian students who meet certain conditions, including those who have been granted a nonimmigrant visa by the State Department, OFAC said. The license authorizes exports of a range of educational courses -- including material related so humanities, law, business, technology and science -- to students who cannot be in the U.S. due to the COVID-19 pandemic. OFAC said it also authorizes “the exportation of certain software to facilitate the participation of certain Iranian students in certain online educational activities.” The actions are authorized through 12:01 a.m. EDT on Sept. 1, 2021.
New U.S. restrictions and prohibitions on remittances to Cuba will “directly harm the Cuban people” and are a “direct attack” on family remittances, the Cuban government said Oct. 28. “Doing so in the middle of a pandemic corroborates the US government’s cynicism, opportunism and contempt for the Cuban people,” the Cuban government said.
The Office of Foreign Assets Control amended and reissued its Yemen Sanctions regulations to include more guidance, general licenses and statements of licensing policy, OFAC said in a final rule released Oct. 28. The rule, which takes effect Oct. 29, provides a more “comprehensive” set of regulations aimed to “provide further guidance to the public.” The rule mainly adds clarifications, new definitions and specifies when certain transactions are authorized by general licenses. New general licenses now included in the regulations authorize certain transactions relating to “investment and reinvestment of certain funds, payments for legal services from funds originating outside the United States, and official activities of international organizations,” OFAC said.
The Office of Foreign Assets Control on Oct. 26 updated 10 frequently asked questions and published one new FAQ to provide guidance on its most recent update to the Cuban Assets Control Regulations (see 2010230024). OFAC’s new FAQ outlines which general licenses the change affects and clarifies how the restrictions apply to entities on the State Department’s Cuba Restricted List. The agency also clarified that effective Nov. 26, people subject to U.S. jurisdiction will no longer be able to process remittances to or from Cuba “through [Financiera Cimex, called] FINCIMEX or any other entity or subentity on the [Cuba Restricted List].”
The Office of Foreign Assets Control sanctioned eight people, 11 entities and two vessels for operating in Iran’s oil sector and supporting the country’s Islamic Revolutionary Guard Corps-Qods Force, OFAC said Oct. 26. OFAC also issued an updated Iran-related general license and amended six frequently asked questions.
The Office of Foreign Assets Control amended the Cuban Assets Control Regulations to further deny the Cuban government’s access to remittance-related funds, OFAC said in a final rule released Oct. 23. The rule amends the scope of certain general licenses to remove “remittance-related general authorizations” involving entities on the Cuba Restricted List, OFAC said. The change will limit those agencies’ access to remittances, “including in their role as intermediaries or in their receipt of fees or commissions from processing remittance transactions.” The rule will take effect Nov. 27. The changes follow a set of new Cuba sanctions and restrictions announced by OFAC in September that created the Cuba Restricted List, placing restrictions on lodging, research and other activities (see 2009230029).
The Office of Foreign Assets Control announced a range of sanctions targeting 17 major Iranian banks for operating in the country’s financial sector and one Iranian bank for being affiliated with the Iranian military. The agency also issued a general license authorizing certain transactions with the banks and announced a 45-day wind-down period for activities involving non U.S. people and companies.
The Office of Foreign Assets Control on Oct. 6 extended a general license related to Petroleos de Venezuela and updated a frequently asked question. General License No. 5E, which replaced No. 5D (see 2007150018), authorizes certain transactions with PdVSA involving an 8.5% bond on or after Jan. 19, 2021. OFAC updated a Venezuela FAQ to reflect the change. The license was scheduled to expire Oct. 20.
The Office of Foreign Assets Control amended its Weapons of Mass Destruction Proliferators Sanctions Regulations and its Iranian Transactions and Sanctions Regulations, the agency said in a notice released Sept. 30. The final rule revises a note that describes how people designated under the WMD regulations for North Korea are identified in OFAC’s Specially Designated Nationals List and amends the ITSR to “refine” a general license. The rule is effective on Oct. 1.