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
Francesca M.S. Guerrero
Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some of their most challenging international transactions, involving dealings in high-risk jurisdictions or with high-risk counterparties. Francesca also counsels companies through all phases of internal investigations of potential trade and antibribery violations and represents companies across industries before related government agencies.
United States Imposes New Russia-Related Export Restrictions
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…
President Biden Sanctions Nord Stream 2 AG as a Result of Russia’s Invasion of Ukraine
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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OFAC Implements Additional Sanctions on Russian Financial Sector and Individuals
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…
President Biden Imposes Sanctions Regarding Russia’s Efforts to Undermine Ukraine
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…
BIS Adds 33 Chinese Companies to the Unverified List
Effective February 8, 2022, the Department of Commerce’s Bureau of Industry and Security (BIS) has added 33 Chinese companies to its Unverified Listed. The Unverified List contains the names and addresses of foreign persons who are or have been parties to a transaction involving the export, reexport, or transfer (in-country) of items subject to the…
CBP Issues Notice of Finding that Certain Palm Oil and Derivative Products from Malaysia Involve Forced Labor
U.S. Customs and Border Protection (CBP) has issued a “Notice of Finding” in which it has determined that certain palm oil and derivative products made wholly or in part with palm oil produced by Sime Darby Plantation Berhad, its subsidiaries, and joint ventures with the use of convict, forced or indentured labor, are…
CBP Issues WRO for Seafood Products Imported from the Dalian Ocean Fishing Company
On May 28, 2021, the U.S. Customs and Border Protection (CBP) issued a press release announcing that the CBP had issued a Withhold Release Order (WRO) for imports of seafood products from Dalian Ocean Fishing Co., Ltd., a Chinese entity, “based on information that reasonably indicates the use of forced labor in the entity’s fishing…
