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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…

On April 8, 2022, President Joseph Biden signed into law H.R. 7108, the Suspending Normal Trade Relations with Russia and Belarus Act, and H.R. 6968, the Suspending Energy Imports from Russia Act. Both pieces of legislation passed the Senate and House of Representatives on April 7, 2022.

The Suspending Normal Trade Relations with…

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…

The Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule adding 120 Russian and Belarusian companies to the Entity List. Ninety-five companies (24 Belarusian entities and 71 Russian entities) are being added as they have been determined to be “military end users.” These entities will also be subject to the Russia/Belarus…

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…

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

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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. …

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…