February 2022

On February 25, the Office of Foreign Assets Control (OFAC) placed on the Specially Designated Nationals (SDN) List Russian President Vladimir Putin, Foreign Minister Sergei Lavrov, Minister of Defense Sergei Shoigu and Chief of the General Staff of the Russian Armed Forces, First Deputy Minister of Defense, and General of the Army Valery Gerasimov.  Specific…

On February 24, 2022, the Department of Treasury’s Office of Foreign Assets Control (OFAC) again expanded sanctions against Russia in response to its invasion of Ukraine by designating numerous Russian and Belarusian financial institutions to the Specially Designated Nationals and Blocked Persons (SDN) List, and Russian financial institutions to the Non-SDN Menu-Based Sanctions (MBS) List…

On February 24, 2022, in response to Russia’s invasion of Ukraine, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a final rule, “Implementation of Sanctions Against Russia Under the Export Administration Regulations (EAR),” adding new Russia export license requirements and making licensing policies more stringent. The final rule is effective…

On February 23, 2022, President Joseph Biden released a statement announcing that the United States was imposing sanctions on Nord Stream 2 AG and its corporate officers.  Effectively immediately, Nord Stream 2 AG has been designated and placed on the Department of Treasury’s Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) List.

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On February 22, 2022, the Office of Foreign Assets Control (OFAC) expanded sanctions against Russia through blocking sanctions against two major Russian state-owned financial institutions, additional restrictions on Russian sovereign debt, sanctions on five Putin/Kremlin-connected elites, and the designation of several vessels. This follows the issuance of comprehensive sanctions on the territory recognized by Russia…

On February 21, 2022, in response to Russia’s recognition of the so-called Donetsk People’s Republic (DNR) and Luhansk People’s Republic (LNR) regions of Ukraine as “independent states,” President Biden issued Executive Order (EO) 14065 prohibiting certain transactions with respect to the DNR or LNR or such other regions of Ukraine (collectively, “Covered Regions”) as may…

On February 15, 2022, the Office of the U.S. Trade Representative (USTR) released its annual 2021 Report To Congress on China’s WTO Compliance. Upon the release of the report, USTR Katherine Tai said:  “China has not moved to embrace the market-oriented principles on which the WTO and its rules are based … [but] has…

On February 14, 2022, the Department of State’s Directorate of Defense Trade Controls (DDTC) released Revision 5.0 of its Guidelines for Preparing Agreements. Under the International Traffic in Arms Regulations (ITAR), an “agreement” approved by the Office of Defense Trade Controls Licensing (DTCL) is required for the provision of a defense service, transfer of manufacturing…

On February 16, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) published in the Federal Register a final rule adding formal regulations to implement previously announced sanctions regarding Chinese Military-Industrial Complex companies. These formal regulations are the result of a November 12, 2020, Executive Order (EO) 13959 issued by former President…

The Executive Office of the President, via the National Science and Technology Council, has released an updated list of advanced technologies that are potentially significant to U.S. national security. This list updates and revises the initial critical technologies list identified in the October 2020 report, “National Strategy for Critical and Emerging Technologies.” See Update of…