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In the latest effort to address Russia’s invasion of Ukraine, on September 2, 2022, the G7 Finance Ministers issued a statement confirming their intention to finalize and implement a price cap with respect to Russian-origin oil. As described, the plan would implement a comprehensive prohibition of services which enable maritime transportation of Russian-origin crude oil…

On August 19, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued two Russia-related General Licenses (GL) authorizing certain limited activities with Russian financial institutions which have been blocked and designated on the Specially Designated Nationals (SDN) List.

Placement on the SDN List results in all property and interests in property…

On August 2, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) added further Russian individuals, entities and vessels to its Specially Designated Nationals (SDN) List.  The designations include numerous Russian individuals connected to Russia President Vladimir Putin, as well as multinational companies Investitsionnaya Kompaniya MMK-FINANS (an investment and financial copany) and…

On July 14, 2022, the Department of Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 44 authorizing transactions ordinarily incident and necessary to the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of tax preparation or filing services to any…

On July 14, 2022, the Department of Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 30A authorizing transactions through December 16, 2022 involving SEFE Securing Energy for Europe GmbH (formerly known as Gazprom Germania GmbH) or any entity in which SEFE Securing Energy for Europe GmbH owns, directly or indirectly, a 50…

On July 14, 2022, the Department of Treasury’s Office of Foreign Assets Control (OFAC) released a food security fact sheet on Russian sanctions and agricultural trade and an amended General License (GL) 6B to broaden the scope of the authorizations relating to transactions involving agricultural and medical products. The Department’s press release emphasized that “[a]gricultural…

On July 7, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 40A, “Authorizing Certain Transactions Involving the Exportation or Reexportation of Liquefied Petroleum Gas to Venezuela.”  This general license continues authorization of all transactions and activities related to the exportation or reexportation, directly or indirectly, of…

On June 28, 2022, The Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned 70 entities and 29 individuals involved in Russia’s defense industrial base.  In addition, the Department of State impose visa restrictions on 511 Russian military officers, and sanctioned an additional 45 entities and 29 individuals.  The designations and placement of…

On June 28, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC), in consultation with the Departments of Commerce and State, issued a determination prohibiting gold imports from Russia, the country’s largest non-energy export, effective immediately. According to the determination, gold imports of Russian Federation origin are prohibited, except to the extent…

On June 14, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued amended Russia-related General License No. 8C extending the authorization to conduct transactions involving the Central Bank of Russia and certain Russian banks that are related to energy until December 5, 2022.  The original General License No. 8, issued on…