The Trump Administration has announced multiple U.S. sanctions measures over the past several weeks, further tightening the sanctions on Iran and imposing additional measures on Venezuela and its allies, Cuba and Nicaragua.
With respect to Iran, the Secretary of State announced on April 22 that the United States would end certain sanctions relief it had afforded to eight countries that previously demonstrated they were making significant reductions in Iranian crude oil purchases. Now, companies and financial institutions that participate in or support purchases by such countries could be exposed to certain U.S. secondary sanctions for purchases by such countries of Iranian petroleum or petroleum products after May 1. Financial institutions in those countries also could now be exposed to U.S. secondary sanctions for conducting or facilitating significant transactions with the Central Bank of Iran, except humanitarian trade. On April 8, the Secretary also designated Iran’s Islamic Revolutionary Guard Corps (“IRGC”) as a Foreign Terrorist Organization (“FTO”), further escalating the scope and severity of U.S. sanctions targeting the IRGC.
In addition, on April 17, the Trump Administration took a series of related actions that White House National Security Advisor John Bolton described as targeting the “troika of tyranny” – his term for Cuba, Venezuela, and Nicaragua. With respect to Cuba, the Administration fully activated for the first time a statutory provision that allows U.S. nationals to sue persons they contend are trafficking in confiscated Cuban property to which they have a claim. Mr. Bolton also previewed further tightening of Cuba sanctions in the areas of travel, remittances, and payments.
In parallel, the Administration added Venezuela’s central bank to the Treasury Department’s List of Specially Designated Nationals and Blocked Persons (the “SDN List”), and designated for sanctions a Venezuelan government official, a senior Nicaraguan political leader, the Nicaraguan subsidiary of a Venezuelan bank, and multiple non-Venezuelan vessels that had transported Venezuelan oil to Cuba.
Collectively, these measures underscore the importance of careful attention to the rapidly evolving U.S. sanctions landscape.
