March 3, 2020 - Yesterday, LSTA issued an updated version of the “LSTA Regulatory Guidance: US Sanctions Issues in Lending Transactions” which can be found here. The blacklined version which shows the changes made to the March 2019 publication can be found here.

This latest update addresses new developments, including with respect to:

• Iran and the reinstatement by the United States of secondary sanctions authorities that had been lifted or waived under the Joint Comprehensive Plan of Action (JCPOA) that target certain sectors of the Iranian economy;
• Russia and the US government’s imposition of a second round of Chemical and Biological Weapons Control and Warfare Elimination Act (CBW Act) sanctions on Russia (notably the sanctions continue the United States’ opposition to the extension of any loan to Russia by international financial institutions);
• Venezuela and the US government’s imposition of blocking sanctions on the government of Venezuela and the US sanctions that have targeted non-Venezuelan sources of support for the Maduro regime; and
• OFAC’s 2019 Compliance Framework.

I would like to thank Jeanine McGuinness of Orrick for acting as our external counsel in this area and keeping us informed of the latest developments.