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The third quarter of 2019 saw continued activity across a wide spectrum of U.S. sanctions programs. Pressure against the Maduro Regime reached new heights as OFAC sanctioned the entire Government of Venezuela, simultaneously threatening punitive measures against its international trading partners. As the continued viability of the Iran nuclear deal was thrown into further doubt, OFAC escalated its use of U.S. secondary sanctions by designating several major Chinese shipping companies for continuing to transport Iranian oil exports. Meanwhile, the U.S. resumed pressure on North Korea following a lack of progress in denuclearization talks and imposed new sanctions on Russia for its alleged involvement in chemical weapons attacks and election interference. Finally, as European courts begin giving effect to the E.U. blocking statute, one recent U.K. court decision affirmed the ability of non-U.S. banks to contractually mitigate their exposure to certain U.S. “secondary sanctions.”
