2022

On March 4, 2022, the Department of Commerce’s Bureau of Industry and Security (BIS) announced further sanctions to target Russia’s strategic oil/gas and military/defense sectors. BIS stated that the actions are intended to further restrict access to U.S. commodities, software, and technology in order to limit Russia’s “ability to raise revenue from the sale of…

On March 3, 2022, President Joseph Biden announced that the United States was sanctioning an extensive list of “Russian elites” and their family members. In a White House press release, the president stated that, “[t]hese individuals and their family members will be cut off from the U.S. financial system, their assets in the United…

On March 2, 2022, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule that has added new license requirements and review policies for Belarus to the Export Administration Regulations (EAR) which now subject Belarus to the same sanctions that were imposed on Russia under the EAR effective February 24, 2022.…

On March 2, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) provided clarifying guidance on the implementation of several of its sanctions involving Russia.  In doing so, OFAC noted that since implementation of the sanctions, “Russia has taken steps to use exporters to act as their agents and help them raise…

The Department of State’s Directorate of Defense Trade Controls (DDTC) announced on February 25, 2022, that effective immediately, DDTC has implemented a policy of denial for any licenses or other approvals under the International Traffic in Arms Regulations (ITAR) for exports, reexports, retransfers, temporary imports of, and brokering activities related to defense articles and defense…

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…