On March 2, 2023, the Departments of Commerce, Justice and the Treasury issued a joint Compliance Note cautioning financial institutions and multinational companies subject to U.S. jurisdiction to “be vigilant against efforts by individuals or entities to evade sanctions and export control laws.” The Compliance Note emphasizes the “unprecedented scope and scale” of sanctions against

On the one-year anniversary of Russia’s invasion of Ukraine, President Joseph Biden on February 24, 2023, issued a Proclamation on Adjusting Imports of Aluminum Into the United States to implement: (1) effective March 10, 2023, a 200% import tariff on aluminum articles and derivative aluminum articles that are the products of Russia, and (2) effective

On March 2, 2023, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule adding 37 entities to the Entity List for contributing to Russia’s military/defense industrial base, supporting China’s military modernization, and facilitating or engaging in human rights abuses in Burma and China, including the following:

  • Three entities in Russia,

On February 24, 2023, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule amending the Export Administrations Regulations (EAR) to impose new export control measures on Iran. These measures address the use of Iranian Unmanned Aerial Vehicles (UAVs) (aka, Unmanned Aircraft System (UAS), aka drones) by Russia in its ongoing

On February 24, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued its latest Russia-related determination expanding its use of sanctions authorities to the metals and mining sector of the Russian Federation economy pursuant to section 1(a)(i) of Executive Order (E.O.) 14024. Section 1(a)(i) of E.O. 14024 allows for the

On February 24, 2023, the Department of Commerce’s Bureau of Industry and Security (BIS) issued three Final Rules addressing Russia’s continued war against Ukraine. One rule expands existing industry sector sanctions and export controls already in place toward Russia and Belarus. The other two rules add Russian and third country entities to the Entity List

On February 24, 2023, the first anniversary of Russia’s invasion of Ukraine, the Departments of the Treasury and State implemented further economic sanctions against key industry sectors “in order to further degrade Russia’s economy and diminish its ability to wage war against Ukraine.” These sanctions are being imposed on over 200 individuals and entities, “including

On February 21, 2023, just a few days before February 24, which marks the one-year anniversary of Russia’s invasion of Ukraine, Deputy Secretary of the Treasury Wally Adeyemo spoke on the Biden administration’s “comprehensive strategy to support Ukraine” including ongoing efforts to deny Russia’s ability “to use the money they have to buy the weapons

On February 3, 2023, the Department of the Treasury (Treasury) issued multiple determinations related to the price cap to be set on Russian-origin petroleum products. Treasury also published finalized guidance on the broader price cap policy implemented by the “Price Cap Coalition” – an international coalition that includes the United States, the G7, the European Union

On January 17, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued three amended General Licenses (GLs) regarding the continued authorization of certain limited activities in Russia or involving Russian entities. 

  • Russia-related General License 6C, “Transactions Related to Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates,