The document summarizes changes to the U.S. sanctions program in 2019, including additional sanctions imposed on Venezuela, Iran, Russia, North Korea, and Cuba. Key changes include lifting restrictions on lawsuits over confiscated Cuban property, increasing sanctions on Iran by ending oil waivers for some countries, and adding more Venezuelan and Russian individuals and entities to the Specially Designated Nationals list. The Office of Foreign Assets Control also published new guidance on compliance commitments and increased penalties through enforcement actions.

1. INSIGHT
May
2019
OFFICE OF FOREIGN ASSETS CONTROL: 2019 CHANGES
This year has brought a number of changes to the U.S. Sanctions Program,
including those related to Venezuela, Iran, Russia, North Korea and Cuba

2. Sia Partners | INSIGHT | OFFICE OF FOREIGN ASSETS CONTROL: 2019 CHANGES | May 2019
Overview of Office of Foreign
Assets Control (“OFAC”)
Regulation in 2019
The year 2019 has brought many changes to
the U.S. Sanctions Program and navigating
these changes can be challenging for financial
institutions. The Trump Presidency has been
very active in driving the many changes in the
U.S. Sanctions Program. For example, there
have been 26 rounds of sanctions against Iran
during the Trump Presidency. Additionally,
there have also been changes to the
Venezuela, Russia, North Korea and Cuba
sanctions programs. Further, OFAC has
continued to use secondary sanctions to
extend the reach of its sanctions regulations.
Moreover, OFAC has taken an aggressive
approach to enforcement, which was reflected
in OFAC’s actions taken against entities not in
compliance with applicable regulations. In this
paper, we will go over the notable changes
made and guidance issued thus far in 2019.
Secondary Sanctions: Secondary sanctions
involve additional economic restrictions
designed to inhibit non-U.S. parties abroad
from doing business with a target of primary
U.S. sanctions. Should a non-U.S. company
conduct business with an SDN, OFAC has the
power to designate that non-U.S. company,
placing that company on the SDN List
itself. The consequences would be
prohibiting all U.S. Persons from
doing any business with it. The U.S. currently
has secondary sanctions within its sanctions
programs against Iran, North Korea, and even
Russia.
Settlement Actions: OFAC has taken an
aggressive approach to enforcement in the
recent past. During 2018, OFAC announced 7
settlements actions for a total of $71,510,561.
During the first 4½ months of 2019, OFAC
completed 14 settlement actions for a total of
$1,278,349,451. This represents twice as
many settlement actions coupled with 1687%
increase in penalties than all of 2018.
A Framework of OFAC Compliance
Commitments: On May 2, 2019, OFAC
published “A Framework of OFAC Compliance
Commitments”, in order to provide
organizations subject to U.S. jurisdiction, as
well as foreign entities that conduct business in
or with the United States or U.S. persons, or
that use U.S.-origin goods or services, with a
framework on the essential components of a
sanctions compliance program. It is significant
because it represents the most detailed
statement on the best practices that
companies should follow to ensure compliance
with U.S. sanctions laws and regulations. This
document also includes an appendix that offers
some of the root causes of apparent violations
of U.S. economic and trade sanctions
programs OFAC has identified during its
investigative process.
Cuba
On April 17, 2019, President Trump lifted long-
standing limitations on American citizens
seeking to sue over property confiscated by
the Cuban regime after the revolution led by
Fidel Castro six decades ago. Title III of the
Cuban Liberty and Democratic Solidarity
(LIBERTAD) Act of 1996, [commonly known as
the Helms-Burton Act] authorizes current U.S.
citizens and companies whose property was
confiscated by the Cuban government on or
after January 1, 1959 to bring suit for monetary
damages against individuals or entities that
“traffic” in that property. The policy rationale
for this private right of action was to provide
recourse to those whose property was seized
by the Castro regime. As part of the statutory
scheme, Congress provided that the President
may suspend this private right of action for up
to six months at a time, renewable
indefinitely. In the past, Presidents of both
parties have consistently suspended that
statutory provision in full every six
months. This changed on May 2, 2019, when
the suspension was effectively lifted.
Iran
The U.S. has a long history imposing
restrictions on business activities in Iran, dating
back to 1979 following the seizure of the U.S.
Embassy in Tehran. The latest news on new
sanctions imposed on Iran include the U.S. re-
imposing sanctions on Iran in late 2018 that
had been lifted or waived under the JCPOA
(Iran nuclear deal). These sanctions target
critical sectors of Iran’s economy, such as the
energy, shipping and shipbuilding, and
financial sectors. These designations
demonstrate the United States’ current
approach to isolate and deny funding to the
Iranian regime. On April 22, 2019, the Trump
Administration announced that the U.S.
government will be abolishing the significant
reduction exceptions that had allowed energy
companies in Italy, Greece, Japan, China,
South Korea, Taiwan, Turkey and India to

3. Sia Partners | INSIGHT | OFFICE OF FOREIGN ASSETS CONTROL: 2019 CHANGES | May 2019
purchase Iranian oil without being subject to
U.S. sanction penalties and enforcement
actions.
Most recently, OFAC targeted Iran’s steel,
aluminum, copper, and iron industries, which
are vital to its economy. The new sanctions
were added by the Trump Administration after
Iran announced its partial withdrawal from the
global 2015 nuclear deal.1
The Trump Administration has made sanctions
central to its efforts to apply “maximum
pressure” on Iran’s regime. President Trump’s
attempt to drive down Iranian oil sales has
tested key U.S. relationships around the world,
including with China, at a time when leaders of
the world’s two largest economies are
negotiating a trade deal. The Iranian dispute
also highlights the growing gap between the
U.S. and Turkey, NATO allies that have been
driven apart by differences over foreign policy
issues concerning Syria to Russia2. Lastly, this
change in OFAC’s program has caused a
growing divide between U.S. and European
Union sanction approaches. Global Financial
Institutions will need to review their current
client populations against the updated SDN
lists in order to comply with OFAC’s Iranian
Sanctions Program.
Venezuela
The political crisis in Venezuela has been
escalating since Nicolas Maduro started his
second term of office on January 10, 2019.
Many foreign governments, except Cuba and
Russia3, refuse to recognize him as President
of Venezuela. U.S. Secretary of State, Michael
Pompeo, has said "Using sanctions, visa
revocations and other means, we pledge to
hold the regime and those propping it up
accountable for their corruption and their
repression of democracy."
Following are the most recent and important
changes made to the SDN lists:
• On January 8, 2019, OFAC sanctioned
seven Venezuelan individuals and 23
1
https://www.washingtonpost.com/world/middle_east/us-
sanctions-to-hit-irans-metals-industry-a-major-
employer/2019/05/09/881ee52c-727b-11e9-9331-
30bc5836f48e_story.html?utm_term=.9f02c9d2e67b
2
https://www.bloomberg.com/news/articles/2019-04-
26/turkey-says-it-s-pushing-back-against-trump-s-iran-sanctions
3
https://www.aljazeera.com/news/2019/01/venezuela-crisis-
latest-updates-190123205835912.html
entities involved in a corruption
scheme designed to take advantage of
the Government of Venezuela’s
currency exchange practices. As a
result of this action, all property and
interests in property of those
designated who subject to or transiting
U.S. jurisdiction are to be blocked, and
U.S. persons generally became
prohibited from engaging in
transactions with them. - Executive
Order (E.O.) 13850.
• On April 5, 2019, OFAC designated
two companies operating in the oil
sector of the Venezuelan economy,
pursuant to E.O. 13850, as amended.
Additionally, OFAC identified a vessel,
owned by one of the two companies
that transported oil from Venezuela to
Cuba, as blocked property.
Separately, OFAC also identified 34
vessels as blocked property of
Petroleos de Venezuela, S.A., which
was designated on January 28, 2019,
for operating in the oil sector of the
Venezuelan economy.
• On April 12, 2019, OFAC designated
another four companies that operate in
the oil sector of the Venezuelan
economy. Additionally, OFAC
identified nine vessels, some of which
transported oil from Venezuela to
Cuba, as blocked property owned by
the four companies.
• Most recently, on April 17, 2019,
OFAC continued to expand sanctions
against Venezuela by adding the
Central Bank of Venezuela (Banco
Central de Venezuela) to the SDN List.
Russia
OFAC had instituted Ukraine/Russia-related
sanctions in a program effective March 6,
2014, when President Obama declared a
national emergency to deal with the threat
posed by the actions and policies of certain
persons who had undermined the democratic
processes and institutions in Ukraine. Since
2014, OFAC’s Russian Sanctions program has
become more comprehensive. On March 15,
2019, the U.S., EU, and Canada took
coordinated action in response to Russia’s
continued aggression toward the Ukraine by
imposing sanctions on individuals who
orchestrated the November 25, 2018 attack on
three Ukrainian naval vessels near the Kerch

4. Sia Partners | INSIGHT | OFFICE OF FOREIGN ASSETS CONTROL: 2019 CHANGES | May 2019
Strait. This action demonstrated that Russia’s
aggression against Ukraine was met with
disapproval by the U.S. and its Trans-Atlantic
allies. 4
Currently, more than 700 Russian individuals
and companies have been targeted by U.S.
sanctions.5 Some top Russian state banks and
energy companies are effectively barred from
obtaining financing through U.S. banks and
markets. The SDN list includes Russian
billionaires such as Oleg Deripaska and Viktor
Vekselberg; close political allies of Putin
including his former Chief of Staff Sergei
Ivanov and Dmitry Rogozin, a deputy prime
minister from 2011 to 2018; and large
corporations such as Rosneft PJSC, Gazprom
PJSC, Sberbank PJSC and VTB Group.
The U.S. Congress has recently debated a
proposal for new sanctions related to Putin’s
involvement in the U.S. Presidential elections.
Thus far, any proposals and bills have not
progressed in the Senate. Global Financial
Institutions and companies should stay alert for
potential changes to OFAC’s Russian
Sanctions Program.
North Korea
OFAC’s North Korean sanction program is one
of its most comprehensive sanctions programs
in existence. On March 22, 2019, OFAC
imposed new sanctions on two Chinese
shipping companies that have been helping
North Korea evade international sanctions
programs. These sanctions were the first
imposed by OFAC on North Korea since late
last year and came less than a month after a
summit meeting between President Donald
Trump and Kim Jung-Un. 5 President Trump’s
goal for the Hanoi summit was to grant some
sanctions relief to North Korea in exchange for
denuclearization of North Korea, but the
president was unsuccessful. However, days
after OFAC issued these additional sanctions,
President Trump ordered the withdrawal of the
additional sanctions. OFAC’s North Korean
sanctions program will change based upon
North Korea’s approach to denuclearization.
Conclusion
There have been and will be extensive
changes to OFAC’s Sanctions Program in
4
https://www.state.gov/r/pa/prs/ps/2019/03/290382.htm
5
https://wapo.st/2Qfxryn
2019. The U.S. Government’s foreign policy
can easily change at any time due to many
political factors. The Russian, North Korean,
Iranian, and Venezuelan OFAC’s Sanctions
Programs are most likely to be impacted this
year. If Venezuela’s President Nicolas Maduro
does not change his policies and continues to
remain in office, OFAC’s Venezuelan
Sanctions Program will likely become more
comprehensive. The current OFAC Iranian
Sanctions Program is at odds with much of
Europe and other U.S. allies. It is crucial that
Global Financial Institutions and companies
that want access to the U.S. financial markets
comply with recent additions to OFAC’s Iranian
Sanctions Program.
In response to all of the comprehensive
changes to OFAC’s sanctions programs in
2019, U.S. and Global Financial Institutions
and Corporations need to closely follow
OFAC’s guidance issued on May 9th, 2019
that directs U.S. organizations and those doing
business in or with the U.S. to incorporate five
key elements into their sanctions compliance
programs, namely: (1) management
commitment; (2) risk assessment; (3) internal
controls; (4) testing and auditing; and (5)
training. Ensuring that organizations
incorporate these five key elements into their
sanctions compliance program is crucial in
helping protect against potential regulatory
risks and penalties.
Lastly, Sia Partners has noticed that our
financial services clients have been
incorporating additional key elements into their
Sanctions Programs. Following are those key
elements:
• The tracking of all of OFAC’s
announcements as they are released
and issuing internal advisories to all
relevant parties, including business
lines;
• Conducting wholesale analyses on
clients once SDN lists are updated or
new sanctions are announced to
determine whether any of their clients
have direct exposure as a result of
additions to the SDN list;
• Maintaining approved or prohibited
bond lists, to provide guidance on the
bonds of SDNs; and,
• Having an on-going screening team in
place in addition to the Sanctions
Compliance staff. The ongoing
screening team monitors and screens
customers regularly rather than only

5. Sia Partners | INSIGHT | OFFICE OF FOREIGN ASSETS CONTROL: 2019 CHANGES | May 2019
during periodic review or during trigger
events.
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material without specific permission of Sia
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6. 6
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