The Trump Administration has continued its escalation of economic sanctions despite the global COVID-19 pandemic, especially with regard to Iran and Venezuela. The Administration recently sanctioned individuals and entities associated with Iran’s Islamic Revolutionary Guards Corp-Qods Force (“IRGC-QF”) and unsealed criminal charges against Venezuela’s (former — depending on who you ask) President Nicolás Maduro and others.
Iran Designations and Venezuela Charges
On March 26, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated 20 Iran- and Iraq-based front companies, senior officials, and business associates that provide support to or act on behalf of the IRGC-QF, including activities that fund terrorist groups. The designations were made pursuant to Executive Order 13224. OFAC designated several other groups and individuals, including Al Khamael Maritime Services (“AKMS”), an Iraq-based company operating out of Umm Qasr port, in which the IRGC-QF has a financial interest. AKMS was designated for being owned, controlled, or directed by, directly or indirectly, the IRGC-QF.
That same day, the U.S. Department of Justice announced criminal charges against numerous current and former Venezuelan Government officials, including Maduro, Diosdado Cabello Rondón (Head of Venezuela’s National Constituent Assembly), Hugo Armando Carvajal Barrios (former director of military intelligence), and Clíver Antonio Alcalá Cordones (former General in the Venezuelan armed forces).
Notably, the U.S. Department of State is offering up to $15 million for information leading to the arrest and/or conviction of Maduro, and monetary awards for information leading to the arrest and/or conviction of others.
Conclusion
In short, the Administration has continued its maximum pressure campaign against Iran and Venezuela, despite the global pandemic. We will continue to closely monitor events in this space and will report on any further developments.
If you have any questions or concerns about U.S. sanctions, please contact Bruce G. Paulsen (212-574-1533), Andrew S. Jacobson (212-574-1477), or Noah S. Czarny (212-574-1642) at Seward & Kissel’s Sanctions Practice Group.
Seward & Kissel has established a COVID-19 Resource Center on our web site to access all relevant alerts that we distribute.
