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
OFAC and State Department Add Over 200 Russia-Related Individuals and Entities to SDN 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
Department of the Treasury Previews Additional Sanctions on Russia
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
Treasury Publishes Final Guidance on the Russian Oil Price Cap
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
OFAC Amends Several Russia-Related General Licenses
- Russia-related General License 6C, “Transactions Related to Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates,
OFAC Publishes Preliminary Guidance on Price Cap to Be Placed on Petroleum Products of Russian Origin
On December 30, 2022, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published preliminary guidance on how the United States will implement a price cap policy on petroleum products of Russian origin. OFAC notes that with this preliminary guidance the agency will likely “take a similar approach for Russian petroleum products as
BIS Places More Russian Companies on Entity List and Sanctions Alleged Procurement Network
Effective December 16, 2022, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule announcing that it was moving nine Russian companies from the Unverified List to the more restrictive Entity List. BIS stated it has continuously been unable to verify the bona fides of these companies due to the Russian
OFAC Sanctions Additional Russian Financial Institutions and Persons
On December 15, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that it was adding Russian banks and financial services entities as well as additional Russian persons to the Specially Designated Nationals (SDN) List in order to further isolate Russia from global markets. For additional information on these entities and
Treasury Announces Price Cap on Russian Oil
On December 2, 2022, the Department of the Treasury (“Treasury”) issued a Determination pursuant to Executive Order 14071 of April 6, 2022 imposing a price cap of $60 per barrel on seaborne crude oil of Russian origin, effective December 5, 2022. Thus, companies can purchase and/or provide services related to the maritime transport of Russian-origin
Treasury Issues Determination Prohibiting Certain Services Related to the Maritime Transportation of Russian Crude Oil
On November 21, 2022, the Department of the Treasury issued a Determination pursuant to Executive Order 14071 (prohibiting new investment in and the provision of certain services to the Russian Federation, see Update of April 7, 2022), that prohibits the following categories of services related to the maritime transport of crude oil of Russian