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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

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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 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 December 2, 2021, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced the expansion of sanctions against Belarus in response to the Lukashenka regime’s continued “disregard for international norms.” The actions taken by OFAC pursuant to Executive Orders 14038 and 13405 include 35 new designations to the Specially Designated Nationals and…

On August 9, 2021, the White House issued a new Executive Order (EO), “Blocking Property of Additional Persons Contributing to the Situation in Belarus,” which expands existing U.S. sanctions against Belarus to target various sectors. The Treasury Department’s Office of Foreign Assets Control (OFAC) also issued a host of new designations to the Specially Designated…