Global Magnitsky Designation Removal

December 2019

Further to the recent article advising of the designation by OFAC of Ventspils Freeport Authority (“VFA”) on 9 December 2019, please note that on 18 December 2019, OFAC announced the removal of those sanctions.

Simultaneous with the designation of VFA was the designation of Latvian oligarch Aivars Lembergs (Lembergs). OFAC advises that since those designations, the Latvian government passed legislation effectively ending Lembergs’ control of the VFA.

“According to the legislation, the port will be supervised by four representatives appointed by the Latvian government. Lembergs resigned from the Ventspils Freeport Authority on December 10, 2019, where he had previously served as the Chairman of the Board.”

As a result of this latest action, all property and interests in property, that had been blocked solely as a result of the VFA’s designation, are unblocked and all otherwise lawful transactions involving US persons and the VFA are no longer prohibited.

In addition, for non-US persons, the risk of being sanctioned under Executive Order 13818, which authorises sanctions against “any person who is determined to have materially assisted or provided financial, material or technological support for, or goods or services in support of any person whose property and interests in property are blocked under…” EO 13818, has now dissipated.