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”;
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BIS Adds 71 Russian and Belarusian Companies to Entity List
On June 2, 2022, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule adding 71 entities located in Russia and Belarus to the Entity List in further response to Russia’s invasion of Ukraine. These entities have been determined by the U.S. government to be acting contrary to the national security…
BIS Creates Russia Export Control Resources Web Page
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…
SEC Issues Sample Comment Letter Regarding Disclosure Obligations Related to Russia’s Invasion of Ukraine
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…
Russia Sanctions Disrupt Automotive Supply Chains and Production
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,…
BIS Expands Export Restrictions on Russia and Belarus
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…
BIS Adds 120 Russian and Belarusian Companies to Entity List
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…
Summary of Recent Financial and Comprehensive Sanctions Related to the Ukraine-Russia Crisis
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
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Biden Imposes Sanctions on Belarus for “Enabling” Russia’s Invasion of Ukraine
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.…
OFAC Further Expands Sanctions Against Belarus and Russia’s Financial Sectors
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…