In recent weeks, the U.S. Department of Treasury, Office of Foreign Assets Control (“OFAC”) has updated the sanctions regulations it administers against Libya and North Korea. These recently implemented sanctions continue OFAC's trend towards precise, targeted sanctions; moreover, the way in which OFAC amended its sanctions on North Korea could have implications for U.S. sanctions on Cuba.

In November 2010, OFAC promulgated the North Korea Sanctions Regulations (the "NKSR"), 31 C.F.R. pt. 510, pursuant to the International Emergency Economic Powers Act (“IEEPA”), 50 U.S.C. § 1701 et seq. The United States has maintained sanctions against North Korea for many years; until recently, those sanctions existed under the authority of the Trading With the Enemy Act ("TWEA"). See 50 U.S.C. App. 1 et seq. In June 2008, however, by Proclamation 8271, President George W. Bush terminated restrictions on North Korea issued under the authority of TWEA. See 73 Fed. Reg. 36,785 (June 26, 2008). At the same time, pursuant to Executive Order 13466, President Bush continued most sanctions on North Korea under IEEPA. See 73 Fed. Reg. 36,787 (June 26, 2008).