On March 18, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) publicly identified certain commercial and private aircraft that have entered Russia in likely violation of the Export Administration Regulations (“EAR”). BIS provided an initial listing of nearly 100 Boeing aircraft owned and/or operated by Aeroflot, AirBridgeCargo, Aviastar-TU, Azur Air, Nordwind,
On Friday, March 11, 2022, the White House issued Executive Order (“EO”) 14068 announcing more sanctions and export controls against the Russian Federation (“Russia”). Concurrent with that announcement, the U.S. Commerce Department’s Bureau of Industry and Security (“BIS”) released new export controls restricting the flow of “luxury goods” to Russia, Belarus, and Russian/Belarusian “oligarchs and malign actors” while the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued dozens of Specially Designated Nationals and Blocked Persons List (“SDN List”) designations and published four (4) new general licenses.
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In episode 2, Husch Blackwell’s Gregg Sofer and Scott Glabe discuss implications of the United States’ broad and hastily enforced sanctions on Russia with
On March 8, 2022, President Biden issued Executive Order 14066 which prohibits the following actions:
On February 24, 2022, the U.S. imposed sweeping sanctions and export controls actions in response to the Russian Federation’s (“Russia”) “war of choice” against Ukraine. (Husch Blackwell summarized the February 24, 2022 actions in a Client Alert published here, as well as more limited actions on February 21-22 here and here.) The past ten (10) days have featured a flurry of new sanctions and rapidly evolving regulations and executive orders imposed by the U.S. President, the Department of State, the Department of Commerce, and the Department of the Treasury addressing the ongoing Russian invasion of Ukraine. Below are the latest updates in chronological order.
On February 22, 2022, one day after the Russian Federation formally recognized the Donetsk People’s Republic (“DNR”) and Luhansk People’s Republic (“LNR”) of Ukraine as “independent states” and the Biden Administration responded by imposing a sanctions embargo against the DNR and LNR regions, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) took further action against Russia by imposing new sanctions against the Russian financial services sector, Russian oligarchs and their family members. OFAC imposed these additional sanctions using Executive Order 14024 (“EO 14024”), which was issued on April 15, 2021 and which authorizes OFAC to sanction operators in Russia’s technology and defense sectors as well as other sectors as determined by the U.S. Secretary of the Treasury in consultation with the U.S. Secretary of State.
On February 21, 2022, U.S. President Joseph R. Biden Jr. issued an Executive Order (the “Ukraine Order”) in response to action taken earlier in the day by Russian Federation President Vladimir Putin to recognize the Donetsk People’s Republic (“DNR”) and Luhansk People’s Republic (“LNR”) of Ukraine as “independent states”. The DNR and LNR are two separatist bodies which have asserted governmental authority over the Donetsk and Luhansk regions of Ukraine, respectively, without authorization from the Government of Ukraine. In 2014, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) added the DNR and LNR to its Specially Designated Nationals and Blocked Persons List (the “SDN List”) in their capacities as individual entities. Since then, OFAC has also added multiple officials associated with the DNR and LNR to the SDN List.
Effective January 13, 2022, the U.S. Census Bureau’s (“Census”) Automated Export System (“AES”) began issuing a response code 66Q notifying Electronic Export Information (“EEI”) filers whenever they enter an export control classification number (“ECCN”) and destination combination that is prohibited under the Export Administration Regulations’ (“EAR”) destination-based controls. For now, such mismatches in filings will
Russia has amassed more than 100,000 troops at the Ukrainian border, leading the White House to issue a warning on January 25 that the U.S. is “prepared to implement sanctions with massive consequences that were not considered in 2014 [when Russia invaded and annexed the Crimea region of Ukraine]” if Russia “further invades Ukraine”. President
As tensions run high between Washington and Moscow over a possibly imminent Russian invasion of Ukraine, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated today four (4) current and former Ukrainian officials under Executive Order (“EO”) 14024 dated April 15, 2021. In a press release issued earlier today, OFAC asserted the Russian Federal Security Service (“FSB”) “recruit[s] Ukrainian citizens in key positions to gain access to sensitive information, threaten the sovereignty of Ukraine, and then leverage these Ukrainian officials to create instability in advance of a potential Russian invasion.” OFAC also noted that Russian agents have sought to influence U.S. elections since at least 2016.