The Department of the Treasury’s Office of Foreign Assets Control (OFAC) has added multiple new entities and persons to its Specially Designated Nationals (SDN) List after determining that they were involved in attempts to evade U.S. sanctions put in place as a result of Russia’s invasion of Ukraine. OFAC has designated Russian commercial bank PJSC
Sanctions
Russia Sanctions Disrupt Automotive Supply Chains and Production
As of February 22, 2022, President Biden and the Departments of State, Commerce and the Treasury have implemented an array of sanctions and export controls severely restricting international trade and financing involving Russia, Ukraine and Belarus in response to the Russian invasion of Ukraine. These have been primarily imposed and implemented pursuant to executive orders,…
BIS Expands Export Restrictions on Russia and Belarus
On and effective April 8, 2022, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule that expands upon prior export control restrictions placed on Russian and Belarus in response to Russia’s invasion of Ukraine. This rule expands restrictive license requirements to include Commerce Control List (CCL) categories 0-2, which include…
President Biden Announces Ban on New Investment on Russia; Sberbank, Alfa-Bank and Other Entities Designated as SDNs
By Scott E. Diamond** on
On April 6, 2022, President Joseph Biden issued Executive Order, “Prohibiting New Investment in and Certain Services to the Russian Federation in Response to Continued Russian Federation Aggression” (the “April 6, 2022 EO”) , further expanding sanctions against Russia, including measures to ban new investments in Russia and authorizations to prohibit the provision of…
Aerospace, Marine, and Electronics Industry Sectors in Russia Added to Sanctionable Sectors Under Executive Order 14024; OFAC Adds SDN Designations
By Scott E. Diamond** on
On March 31, 2022, Secretary of the Treasury Janet Yellen released a Determination expanding the scope of Section 1(a)(i) of Executive Order 14024 to include aerospace, electronics and marine sectors of the Russian economy as being within the scope of the Executive Order. This Executive Order has been relied upon extensively to implement sanctions against…
OFAC Issues New Russia-Related General Licenses
By Scott E. Diamond** on
On March 24, 2022, the Office of Foreign Assets Control (OFAC) issued two amended general licenses (GL) and two new GLs involving Russia-related sanctions programs. OFAC has also updated its FAQs 1,023 and 1,024 to reflect the changes in GL 17A.
- General License 6A: GL 6 authorized transactions prohibited by the Russian Harmful Foreign
…
President Biden Issues Sanctions on the Russian Duma and Additional Russian Oligarchs and Defense Companies
By Scott E. Diamond** on
On March 24, 2022, President Joseph Biden announced further sanctions toward Russia involving more than 400 individuals and entities, including the Russian Duma and its members, several additional Russian oligarchs, and numerous Russian defense companies. The sanctions were carried out pursuant to Executive Order 14024 which authorizes sanctions against Russia for its harmful foreign activities. …
BIS and OFAC Release Details on Air and Maritime Activities Involving Russia and Ukraine
By Scott E. Diamond** on
On March 18, 2022, the Department of the Commerce’s Bureau of Industry and Security (BIS) identified nearly 100 commercial and private aircraft that have allegedly “flown into Russia in apparent violations of the Export administration Regulations (EAR).” The list identifies planes owned by Russian airlines Aeroflot, AirBridgeCargo and Utair as well as Russian oligarch Roman…
Biden Announces Additional Import and Export Restrictions on Russia
By Scott E. Diamond** on
On March 11, 2022, President Joseph Biden issued an Executive Order (EO) announcing further prohibitions on imports, exports and new investments related to Russia. This announcement was made at the same time that the president and the other G7 leaders of Canada, France, Germany, Italy, Japan and the United Kingdom, as well as the European…
Summary of Recent Financial and Comprehensive Sanctions Related to the Ukraine-Russia Crisis
Key Notes:
- OFAC implemented blocking and other sanctions against major Russian and Belarusian financial institutions.
- OFAC implemented blocking and other sanctions against state-owned enterprises, prominent government officials and other persons or entities.
- OFAC implemented blocking sanctions targeting involvement in the Nord Stream 2 pipeline.
- OFAC implemented sanctions related to Russian government debt.
- The United States
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