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
Ukraine
President Biden Signs Laws Suspending Normal Trade Relations with Russia and Belarus and Suspending Energy Imports from Russia
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…
President Biden Announces Ban on New Investment on Russia; Sberbank, Alfa-Bank and Other Entities Designated as SDNs
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…
BIS Adds 120 Russian and Belarusian Companies to Entity List
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…
Aerospace, Marine, and Electronics Industry Sectors in Russia Added to Sanctionable Sectors Under Executive Order 14024; OFAC Adds SDN Designations
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
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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President Biden Issues Sanctions on the Russian Duma and Additional Russian Oligarchs and Defense Companies
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
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
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…
Biden Calls on Congress to Suspend “Normal Trade Relations” Status of Russia
On March 11, 2022, President Biden called on Congress to pass legislation that will revoke normal trade relations (NTR) with Russia, and announced that the administration “will work closely with Congress to deny Russia the benefits of its WTO membership and ensure that Russian imports do not receive most favored nation treatment” in the U.S.…