On April 17, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) published an Alert warning U.S. persons about possible evasion of the price cap set on Russian-origin oil (see Update of December 5, 2022) and Russian-origin petroleum products (see Update of February 8, 2023) pursuant to Executive
OFAC and State Department Continue to Target Individuals and Entities Facilitating Russian Financial Transactions and Supporting Russia’s Defense Sector
On April 12, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced further efforts to deny Russia’s access to the international financial system through facilitators and their businesses. For example, OFAC has designated and sanctioned the “facilitation network” of Alisher Burhanovich Usmanov, who had previously been placed on OFAC’s Specially Designated
BIS Adds 28 Entities to the Entity List for Supporting Russia’s Military/Defense Industrial Base
On April 12, 2023, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule in which it added 28 entities to the Entity List. The entities are companies located in Armenia , China, Malta, Russia, Singapore, Spain, Syria, Turkey, the United Arab Emirates (UAE), and Uzbekistan. Each was placed on the
USTR Releases President Biden’s 2023 Trade Policy Agenda and 2022 Annual Report
On March 1, 2023, the Office of the United States Trade Representative (USTR) released President Biden’s 2023 Trade Policy Agenda and 2022 Annual Report. According to the report, the 2023 trade agenda will prioritize creating new opportunities for American workers and families, supporting the middle class, driving decarbonization, and creating good-paying jobs. Additionally, the
Commerce, Justice and the Treasury Issue Joint Compliance Note on Evasion of Russia Sanctions and Export Controls
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
UPDATED: President Biden Issues Proclamations Increasing the Tariff Rates on Russian Aluminum to 200% and Significantly Increasing Rates on Other Russian Products
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
BIS Adds 37 Entities to Entity List for National Security Risk Activities Involving Burma, China, Iran and Russia
- Three entities in Russia,
New Export Control Measures on Iran Address Iranian UAVs and Their Use by Russia in War with Ukraine
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
Treasury Issues Determination Adding Russia’s Metal and Mining Sector to E.O. 14024 for Potential Sanctions
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 blocking
BIS Adds Nearly 100 Russia-Related Entities to Entity List and Tightens Other Export Controls and Lists
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