On September 30, 2022, in response to Russia President Vladimir Putin’s illegal effort to annex further Ukraine territory, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule that added 57 entities located in Russia and the Crimea region of Ukraine to the Entity List for supporting the Russian military’s continuing

On September 15, 2022, the Department of the Treasury and Department of Commerce took additional actions to sanction entities and individuals furthering Russia’s aggression against Ukraine and to tighten export controls targeting Russia’s military and defense capabilities.

OFAC Additions to the SDN List

The Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced

On June 27, 2022, President Joseph Biden issued a Presidential Proclamation announcing that the United States was increasing the duty rate to 35% ad valorem on certain products from Russia effective July 28, 2022. The White House indicated that this higher tariff will affect “more than 570 groups of Russian products worth approximately $2.3 billion”;

The Department of Commerce’s Bureau of Industry and Security (BIS) has created a web page offering “Resources on Export Controls Implemented in Response to Russia’s Invasion of Ukraine.” The web page provides convenient links to relevant BIS press releases, fact sheets, and Federal Register notices related to BIS actions involving export controls and

On May 3, 2022, the Securities and Exchange Commission’s Division of Corporation Finance issued a sample comment letter outlining public company disclosure requirements relating to the business impact of Russia’s invasion of Ukraine and the international response.

To the extent material or otherwise required under the SEC’s disclosure framework, the SEC advises that companies should

As of February 22, 2022, President Biden and the Departments of State, Commerce and the Treasury have implemented an array of sanctions and export controls severely restricting international trade and financing involving Russia, Ukraine and Belarus in response to the Russian invasion of Ukraine. These have been primarily imposed and implemented pursuant to executive orders,

On and effective April 8, 2022, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule that expands upon prior export control restrictions placed on Russian and Belarus in response to Russia’s invasion of Ukraine. This rule expands restrictive license requirements to include Commerce Control List (CCL) categories 0-2, which include

The Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule adding 120 Russian and Belarusian companies to the Entity List. Ninety-five companies (24 Belarusian entities and 71 Russian entities) are being added as they have been determined to be “military end users.” These entities will also be subject to the Russia/Belarus

Key Notes:

  • OFAC implemented blocking and other sanctions against major Russian and Belarusian financial institutions.
  • OFAC implemented blocking and other sanctions against state-owned enterprises, prominent government officials and other persons or entities.
  • OFAC implemented blocking sanctions targeting involvement in the Nord Stream 2 pipeline.
  • OFAC implemented sanctions related to Russian government debt.
  • The United States