Transnational Criminal Organizations
Country-Level and Policy-Level Programs. Certain of the sanctions programs are focused on individual countries (the “country-level programs”), while others target specific activities on a global basis such as terrorist and non-proliferation sanctions (the “policy-level programs”). Under a number of the country-level programs (such as Iran, Syria, N. Korea, Cuba and the Crimea region of Ukraine – the “comprehensive sanctions programs”) U.S. persons are prohibited from entering into effectively all business transactions with the targeted country, its government and its nationals, including the export and import of products, technologies and services, payments and investments, subject to exceptions described below.[5] For other country-level programs, such as Russia, Ukraine and Venezuela, certain business activities within the country are prohibited but others are permitted (the “partial sanctions programs”). For example under the Venezuela sanctions program entering transactions with the Government of Venezuela and certain Venezuelan government-owned entities (including Petroleos de Venezuela, SA) are prohibited (along with other restricted activities), but certain other business activities in Venezuela are allowed. In certain cases the program may impose restrictions on sectors of a country’s economy, such as restrictions in the energy, financial services and defense sectors in Russia.