On October 14, 2022, the Departments of Commerce, Treasury and State issued a joint alert regarding the Impact of Sanctions and Export Controls on Russia’s Military-Industrial Complex. The alert provides a summary of the major actions taken by Treasury’s Office of Foreign Assets Control (OFAC) and Commerce’s Bureau of Industry and Security (BIS) with helpful links to official web sites and documents. The overview notes the significant sanctions that have been imposed on Russia’s banking sector as well as sanctions and export restrictions placed on major Russian military, defense, oil and technology companies.

Equally important, the alert serves as an ongoing warning of the risks of supporting Russia’s military-industrial complex. The agencies note that the “intent of our actions is to degrade Russia’s ability to wage its unjust war against Ukraine and prevent Russia from projecting military force beyond its borders.” Since Russia has historically relied heavily on foreign-sourced items to sustain its defense industrial base, the alert indicates that Russia is increasingly attempting to evade U.S. and other allied partners’ sanctions and export controls. These efforts include the use of front companies, intermediaries in third countries, and fraudulent end-user licenses. As such, the alert serves as a reminder by the agencies that existing sanctions authorities allow for the imposition of sanctions “on deceptive or structured transactions or dealings to circumvent any United States sanctions” and that the U.S. government will continue to “use their authorities against persons inside and outside Russia that engage in sanctions evasion or circumvention.”