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 Friday, May 19, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) announced the addition of more than 300 Russian Federation individuals and companies as well…

Continue Reading OFAC and U.S. Department of State Issue New Sanctions and Designates More Than 300 Russian Federation Individuals and Companies Aiding Russia’s War Efforts

Recently, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced the issuance of a $300 million penalty against Seagate Technology LLC and its Singapore affiliate, Seagate Singapore…

Continue Reading BIS Levies Record Penalty for Export Control Violations related to Huawei Shipments

Yesterday, our team published a client alert exploring recent statements made by Deputy Attorney General Lisa Monaco in connection with the Department of Justice’s continued efforts to investigate and prosecute individuals for violating economic sanctions, export controls, and other similar economic crimes. The statements—made at an American Bar Association event last week—demonstrate that export controls continue to rank highly among DOJ’s priorities. Continue Reading DOJ Continues Pursuit of Export Control Violations

The Department of Commerce’s Bureau of Industry and Security (“BIS”) announced today new export controls and Entity List additions designed to further restrict Russia’s ability to maintain its continued war…

Continue Reading BIS Issues New Export Controls and Entity List Additions Targeting Russia on One-Year Anniversary of Invasion

On Friday, February 24, 2023, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued new sanctions against individuals and entities operating in Russia and against those assisting with…

Continue Reading OFAC Issues Sweeping Sanctions to Mark One-Year Anniversary of Russia’s Invasion of Ukraine

On December 16, 2022, the U.S. Commerce Department’s Bureau of Industry and Security (“BIS”) published a rule adding 35 entities from China and one entity from Japan to the Entity…

Continue Reading BIS Adds 35 Chinese Entities to Entity List for Supporting China’s Military Modernization Efforts and Nine Russian Entities for Failure to Complete Satisfactory End-Use Checks

On December 15, 2022, the Office of Foreign Assets Control (“OFAC”) added 18 entities in Russia’s financial services sector to the Specially Designated Nationals and Blocked Persons List (“SDN List”).

Continue Reading OFAC Continues to Take Aim at Russia’s Financial Sector with More SDN Designations

BIS Adds 24 New Entities and Removes One from Entity List

On December 8, 2022, the Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a notice in the…

Continue Reading BIS Adds 24 New Entities and Removes One from Entity List and Extends Deadline for Comments to New Semiconductor Rules

On November 1, 2022, the United States Trade Representative (“USTR”) released the questionnaire it is requesting interested parties to submit for its consideration related to the economic impact of the…

Continue Reading USTR Releases Draft Questionnaire for Section 301 Economic Impact Analysis

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