1. March 10, 2011 U.S. Issues Sanctions Against the Government of Libya
INTERNATIONAL BUSINESS CLIENT ALERT
On February 25, 2011, the U.S. Government imposed sanctions on the Government of
This Alert provides only Libya. Currently, these sanctions target only the Qadhafi regime, but the situation is
general information and changing daily. The primary sanctions block property and interests in property of the
should not be relied upon as Government of Libya (including the Central Bank of Libya and other agencies,
legal advice. For more instrumentalities or controlled entities of the Government of Libya), Qadhafi family
information, contact your
members, senior officials of the Libyan Government, officials who have contributed to
Patton Boggs LLP attorney or
human rights abuses related to political repression in Libya, persons who have provided
material assistance to such persons and those with family relationships, ownership or
the authors listed below.
control over or by, or are agents of, such persons.
Amy Kim The U.S. Treasury Department has specifically excepted from these prohibitions banks
202-457-5667
akim@pattonboggs.com
owned or controlled by the Government of Libya that are organized under the laws of
a country other than Libya, provided that any transaction with such bank does not
Stephen McHale involve the Government of Libya or the blocked persons. Additionally, Treasury
202-457-6344 issued an exception for certain transactions with Libyan diplomatic missions in the
smchale@pattonboggs.com United States. Finally, while lawyers can provide legal services to these blocked entities,
Dan Waltz they cannot get paid for such services without a license from Treasury.
202-457-5651
dwaltz@pattonboggs.com U.S. companies doing business in Libya, U.S. exporters to Libya and U.S. banks will be
primarily impacted by these sanctions. Non-U.S. entities, particularly banks, with ties to
the Libyan Government may also be impacted by these sanctions. Patton Boggs is
WWW.PATTONBOGGS.COM
aware that U.S. government officials have contacted U.S. financial institutions, foreign
banks and their U.S. branches, concerning Libyan government assets. We will continue
to monitor developments in Libya and actions taken by the U.S. government.
Treasury Department documents related to the sanctions are listed here:
Executive Order 13566 of February 25, 2011: Blocking Property and Prohibiting Certain
Transactions Related to Libya:
http://www.treasury.gov/resource-center/sanctions/Programs/Documents/2011_libya_eo.pdf
General License No. 1A:
http://www.treasury.gov/resource-center/sanctions/Programs/Documents/libya2_gl1.pdf
General License No. 2:
http://www.treasury.gov/resource-center/sanctions/Programs/Documents/libya2_gl2.pdf
General License No. 3:
http://www.treasury.gov/resource-center/sanctions/Programs/Documents/libya2_gl3.pdf
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