The latest on Russia sanctions from the International Trade and Supply Chain Team
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Grant focuses his practice on international trade, international compliance, securities, mergers, acquisitions and general corporate matters.

On June 28, 2022, the Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) and the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a Joint Alert urging financial institutions to be vigilant against efforts by individuals or entities to evade BIS export controls implemented in connection with the Russian Federation’s further invasion of Ukraine.  After providing an overview of recent BIS actions in response to Russia’s invasion of Ukraine, the Joint Alert identifies commodities that present “special concern because of their potential diversion to and end use by Russia and Belarus to further their military and defense capabilities,” all of which require a BIS license prior to export or reexport to Russia and Belarus.
Continue Reading U.S. Departments of Treasury and State Expand Sanctions To Restrict Russia’s Access to Services and Economics and Combat Evasion and Backfill Activities

On June 2, 2022, the Office of Foreign Assets Control (OFAC) added new Russian vessels and aircraft used by Russian elites, new top Russian government officials, and their companies and operations to the Specially Designated Nationals (SDN) List for aiding in the continued war effort by Russia against Ukraine.  Notably, these designations include more Russian government officials and oligarchs, and two of the largest mining companies in Russia, Severstal PJSC (Severstal) and Nord Gold PLC (Nord Gold).  This means that U.S. persons cannot engage in any transactions with Severstal or Nord Gold unless authorized by a license.
Continue Reading OFAC and State Department Designate Severstal, Nord Gold and Additional Russians as SDNs

On June 2, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) updated the Export Administration Regulations (“EAR”) to: (i) add 71 entities to the Entity List “for acquiring or attempting to acquire U.S.-origin items in support of Russia’s military”; (ii) issue minor revisions, corrections, and clarifications to its Russia and Belarus export controls; and (iii) increase its administrative disclosure authorities to allow the publication of charging letters prior to a resolution of an administrative case.  The changes went into effect immediately on June 2, 2022 and were published in the Federal Register on June 6, 2022 via two Final Rules available (here) and (here).
Continue Reading BIS Adds 71 Entities to Entity List; Issues Russia/Belarus Corrections and Clarifications; and Updates EAR to Allow Immediate Publication of Charging Letters

Matthew Axelrod, the Assistant Secretary for Export Enforcement at the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”), told a conference held by the Society for International Affairs on May 16, 2022, that his agency is considering major policy changes to its administrative enforcement authorities.  Axelrod said the policy changes, expected to be rolled out in the next few months, are intended to incentivize export compliance by corporations under the Export Administration Regulations (“EAR”). 
Continue Reading BIS Considers More Public and Expensive Consequences for Companies Violating the EAR

On May 8, 2022 the U.S. Department of the Treasury’s (“Treasury”) Office of Foreign Assets Control (“OFAC”) further escalated U.S. sanctions against the Russian Federation (“Russia”) by issuing two Determinations,
Continue Reading OFAC Issues New Sanctions Prohibiting Certain Accounting, Auditing, Corporate Formation and Management Services to Persons in Russia Effective June 7, 2022; And Additional Bank Designations and General Licenses

This blog post covers several new sanctions and export controls that the U.S. government imposed on Russia and Belarus in the time period occurring between March 31, 2022 and April
Continue Reading Summary of Changes in Russia/Belarus Export Controls and Sanctions Occurring From March 31, 2022 to April 22, 2022

On March 30, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) modified and expanded a list of aircraft that have flown into Russia in apparent violation of the Export Administration Regulations (“EAR”).  We more thoroughly discussed the implications of this list – which was first published on March 18, 2022 – in our blog post here.  The updated list adds 73 additional Boeing-manufactured aircraft and modifies tail and/or serial number information for 13 aircraft previously listed on March 18, 2022.  The full list of owners/operators include Aeroflot, AirBridge Cargo, Aviastar-TU, Alrosa, Atran, Azur Air, Nordstar, Nordwind, Pegas Fly, Pobeda, Rossiya, Royal Flight, S7 Airlines, and Utair (FC Chelsea owner Roman Abramovich’s private Gulfstream jet is also on the list).
Continue Reading BIS Modifies and Expands List of Russian-Controlled Aircraft Subject to the EAR Known or Suspected to Have Violated the EAR

On March 24, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) updated the Specially Designated Nationals and Blocked Persons List (“SDN List”) with hundreds of
Continue Reading OFAC Announces Hundreds of New SDN Designations Targeting Russia’s Duma, Defense Sector and Bank Officials; Issues New General Licenses

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.

 
Continue Reading U.S. Imposes More Russian Sanctions and Export Controls on Consumer Items and Luxury Goods, U.S. Dollar-Denominated Banknote Transactions, and Russian Oligarchs