On February 23, 2024, the eve before Russia’s full-scale invasion of Ukraine officially enters its third year, the United States issued another sanctions package against Russia, taking particular aim at Russia’s financial sector, energy production revenue streams, and military-industrial complex. Specifically, the package sanctions more than 500 entities and individuals by having them added

On February 20, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) extended Russia-related General License (GL) 83 by issuing a revised version: GL 83A, “Authorizing Certain Transactions Related to Imports of Certain Categories of Fish, Seafood, and Preparations Thereof Prohibited by Executive Order 14068.” The modified GL 83A maintains the

On February 1, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) published an Oil Price Cap Compliance and Enforcement Alert to provide “[a]n overview of [five] key … evasion methods and [corresponding] recommendations for identifying such methods and [subsequently] mitigating their risks and negative impacts.” The price cap referenced by the

Effective January 25, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) again expanded export controls and sanctions against Russia for its continuing aggression against Ukraine and Belarus for its complicity in such activities. In a Final Rule, BIS is expanding the scope of the Export Administration Regulations’ (EAR) Russian and Belarusian

On January 18, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) again extended previous Russia-related General License (GL) 13 by issuing a revised GL 13H, “Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024,” which states that U.S. persons are authorized to pay taxes, fees, or import

On December 20, 2023, nearly eleven months after publishing its finalized guidance on the implementation of the twin price caps on Russian oil and Russian petroleum products, the Department of the Treasury (“Treasury”) published a revised Guidance on Implementation of the Price Cap Policy for Crude Oil and Petroleum Products of Russian Federation Origin

On December 22, 2023, President Joseph Biden issued Executive Order 14114 (EO) amending EO 14024 by authorizing the imposition of U.S. sanctions on foreign financial institutions that are either facilitating significant transactions on behalf of persons designated for operating in certain key sectors of the Russian economy, or facilitating significant transactions or providing services involving Russia’s

On December 22, 2023, President Joseph Biden amended, among other things, Executive Order (EO) 14068, by additionally authorizing the prohibition on the importation and entry into the United States, including a foreign trade zone located in the United States, of the following products of Russian Federation origin: fish, seafood, and preparations thereof, as well

On December 12, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of State announced sanctions designating numerous additional Russian individuals and entities who have been determined to be assisting in the war against Ukraine and for efforts to evade U.S. sanctions and export controls on Russia. OFAC also