The latest on Russia sanctions from the International Trade and Supply Chain Team
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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

On March 11, 2022, President Biden issued an Executive Order (“EO”) that prohibited the importation into the United States of fish, seafood, and preparations thereof; alcoholic beverages; non-industrial diamonds; and any other products of Russian Federation origin as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State and the Secretary of Commerce.  Because the Executive Order lists no effective date, implementation will be immediate.  No exceptions are listed for such products that are in transit and the EO specifically states that the prohibitions apply “notwithstanding any contract entered into or license or permit granted prior to the date of this order.”

Continue Reading Biden Issues Executive Order Prohibiting Certain Imports and Calls for Congressional Action to Revoke Permanent Normal Trade Relations With Russia

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.


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.

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

On February 10, 2022, the Department of Commerce published a Federal Register notice requesting public comments on the Section 232 exclusions process.  The notice follows the agreement reached between the U.S. and the EU related to the tariff rate quotas for steel and aluminum articles from EU member countries and the President’s January 3, 2022 announcement, Adjusting Imports of Steel into the United States (Proclamation 10328).

Continue Reading Commerce Requesting Public Comments on Section 232 Exclusion Process

The U.S. Department of Commerce (“Commerce”) announced on Friday that it was set to resume trade missions starting as early as March 2022.  Trade missions are government- led programs where members of the trade can meet directly with foreign industries and officials to explore potential business opportunities.  The COVID-19 pandemic brought these missions to a sudden halt in March 2020 and no trade missions have occurred in the past 24 month.  The International Trade Administration (“ITA”) is now preparing to resume in-person trade missions, where possible.

Continue Reading Commerce Trade Missions Set to Resume in March 2022