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
Ukraine
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.…
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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President Biden Bans Imports of Russian Oil, Liquified Natural Gas and Coal
On March 8, 2022, President Joseph Biden signed an Executive Order banning the import into the United States of Russian oil, liquefied natural gas, and coal. The Executive Order bans:
- The importation into the United States of Russian-origin crude oil; petroleum; petroleum fuels, oils, and products of their distillation; liquefied natural gas; coal; and coal
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State Department and OFAC Sanction Russian Defense Entities
On March 3, 2022, the State Department announced that the United States was sanctioning certain Russian companies deemed to design, develop, and produce items that the Russian military is using to attack Ukraine. Specifically, the following 21 entities are being designated pursuant to E.O. 14024, because “they are persons who operate or have operated in…
BIS Expands Russian Oil Industry Sanctions and Adds Russian Companies to the Entity List
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On March 4, 2022, the Department of Commerce’s Bureau of Industry and Security (BIS) announced further sanctions to target Russia’s strategic oil/gas and military/defense sectors. BIS stated that the actions are intended to further restrict access to U.S. commodities, software, and technology in order to limit Russia’s “ability to raise revenue from the sale of…
President Biden Announces Sanctions on “Russian Elites” and “Intelligence-Directed Disinformation Outlets”
On March 3, 2022, President Joseph Biden announced that the United States was sanctioning an extensive list of “Russian elites” and their family members. In a White House press release, the president stated that, “[t]hese individuals and their family members will be cut off from the U.S. financial system, their assets in the United…
Biden Imposes Sanctions on Belarus for “Enabling” Russia’s Invasion of Ukraine
On March 2, 2022, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule that has added new license requirements and review policies for Belarus to the Export Administration Regulations (EAR) which now subject Belarus to the same sanctions that were imposed on Russia under the EAR effective February 24, 2022.…
OFAC Issues Clarifying Guidance on Its Russia Sanctions and Amends Several General Licenses
On March 2, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) provided clarifying guidance on the implementation of several of its sanctions involving Russia. In doing so, OFAC noted that since implementation of the sanctions, “Russia has taken steps to use exporters to act as their agents and help them raise…