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 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

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.
Continue Reading OFAC Sanctions Four Ukrainian Officials for Acting on Russia’s Behalf; Additional Russia Sanctions Could Follow

In an October 21, 2021 interim final rule (“IFR”), the Bureau of Industry and Security (“BIS”) published long-awaited “cybersecurity items” controls in Categories 4 (Computers) and 5, Pt. 1 (Telecommunications) of the Commerce Control List (“CCL”) and followed the IFR up on November 12, 2021 with relevant FAQs.  The IFR will impose new export controls on certain “cybersecurity items” that relate to “intrusion software” or “IP network communications surveillance.” The IFR, originally scheduled to become effective on January 19, 2022, will now become effective on March 7, 2022.  In the January 12, 2022 notice announcing the delay, BIS stated it “may consider some modifications for the final rule” and indicated it would “provide the public with additional guidance.”  Below we describe the IFR as it currently stands.  We will update readers when BIS implements any additional edits to the IFR and/or updates its guidance.
Continue Reading BIS Delays Implementation of New Cybersecurity Items Interim Final Rule

The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) recently issued a final rule amending the U.S. Export Administration Regulations (EAR) to add twenty-seven (27) companies and individuals to the BIS Entity List effective November 26, 2021. These companies and researchers are alleged to have ties to China’s military quantum computing efforts as well as Pakistani nuclear and missile proliferation. The new companies added include:
Continue Reading BIS Blacklists Certain Entities with Ties to China, Pakistan and Russia

On October 5, 2021, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) published a final rule in the Federal Register that places new controls on software and…
Continue Reading BIS Imposes New Export Restrictions on Software for Biological Equipment

In Husch Blackwell’s August 2021 Trade Law Newsletter, you’ll learn about the following updates in international trade and supply chain law:

  • U.S. Customs and Border Protection issued updated guidance

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Continue Reading August 2021 Trade Law Update