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On September 30, 2022, in response to Russia President Vladimir Putin’s illegal effort to annex further Ukrainian 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 9, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) published preliminary guidance on how the United States, in coordination with the other G7 members, will implement a price cap on services related to the maritime transportation of Russian-origin crude oil and petroleum products. OFAC’s preliminary guidance reflects the joint…

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 September 15, 2022, the Department of the Treasury issued a Determination pursuant to E.O. 14071 that prohibits the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a U.S. person, wherever located, of quantum computing services to any person located in the Russian Federation. This determination will take effect…

On September 8, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a revised Russia-related General License (GL) 13B, “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 duties and purchase or receive permits,…

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 16, 2022, the Department of Commerce’s Bureau of Industry and Security (BIS) issued several new Frequently Asked Questions (FAQ) addressing potential red flags for diversion concerns.

Regarding semiconductor foundries, one FAQ asks if there any special red flags that should be considered with regard to parties (e.g., integrated circuit designers) on the Entity…

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…