The latest on Russia sanctions from the International Trade and Supply Chain Team
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Export Controls & Economic Sanctions

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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 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 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 22, 2022, the United States and the United Kingdom announced in a joint statement that the U.S. will halt Section 232 tariffs on imports of steel and aluminum from the U.K, effective June 1, 2022, and that the U.K. will also lift retaliatory tariffs on over $500 million worth of U.S. exports to the U.K.  The Section 232 tariffs were instituted in March 2018 on all imports of steel and aluminum from multiple countries.  …
Continue Reading The United States and the United Kingdom Agree to Cessation of Section 232 Tariffs on Steel and Aluminum

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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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

On March 8, 2022, President Biden issued Executive Order 14066 which prohibits the following actions:

  • The importation into the United States of any “crude oil; petroleum; petroleum fuels, oils, and products of their distillation; liquefied natural gas; coal; and coal products” of “Russian Federation origin”;
  • New investment in the Russian energy sector by U.S. persons, wherever located; and
  • Any approval, financing, facilitation, or guarantee by a U.S. person, wherever located, of any transaction conducted by a non-U.S. person that would be prohibited by Executive Order 14066 if performed by a U.S. person or within the United States.

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Continue Reading President Biden Issues Executive Order Banning U.S. Imports of Russian Origin Oil, Gas, and Coal

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.
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Continue Reading U.S. Imposes More Sanctions and Export Controls against Russia and Belarus

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.  …
Continue Reading OFAC Imposes “First Tranche” of Russia Sanctions Aimed at Russian Banks and Oligarchs

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.
Continue Reading New Executive Order Imposes Sanctions on Donetsk and Luhansk People’s Republics in Ukraine