Sanctions Update – Ventspils Freeport *Update*
19 December 2019
On 18 December Ventspils Freeport Authority was removed from the list of designated entities, and is therefore no longer subject to US sanctions.
10 December 2019
Ventspils Freeport Authority was amongst those entities designated by the U.S. on 9 December under Executive Order 13818, which targets perpetrators of serious human rights abuse and corruption.
Section 1(a)(iii)(A) of the Executive Order authorizes the imposition of sanctions against any person (and so not just a U.S. person) who is determined to have materially assisted or provided financial, material or technological support for, or goods or services in support of, among others, any person whose property and interests in property are blocked under the E.O.
Ventspils Freeport Authority is now blocked under the Executive Order. Therefore, any person providing material assistance to, or goods or services in support of Ventspils Freeport Authority risks the imposition of sanctions as set out in the Executive Order.
OFAC also released Global Magnitsky General License No. 1, which authorizes transactions and activities ordinarily incident and necessary to the wind-down of transactions involving the Freeport until 12:01 eastern standard time on 8 January 2020.
When the Government of Venezuela was sanctioned by the U.S. in August, General License 30, which was not time limited, permitted all transactions and activities ordinarily incident and necessary to operations or use of ports in Venezuela, on the terms set out in that License. No comparable General License has been issued in respect of the Freeport of Ventspils.
For further information and advice, Members can contact North’s sanctions team at sanctions.advice@nepia.com