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

Effective January 1, 2021 duty reductions under the Miscellaneous Tariff Bill (MTB) expired.  Additionally, Congress has not indicated when it might consider a new MTB bill.  As a result of
Continue Reading Miscellaneous Tariff Bill Duty Reductions Have Expired Effective January 1, 2021. Renewal Date Uncertain

On December 19, 2018, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) and the U.S. State Department took multiple sanctions actions related to Russia:

Proposed Delisting of En+ Group, UC Rusal and ESE

OFAC notified Congress of its intent to remove En+ Group plc (“En+ Group”), UC Rusal plc (“UC Rusal”) and JSC EuroSibEnergo (“ESE”) from its Specially Designated Nationals and Blocked Persons List (the “SDN List”) within thirty (30) days from December 19, 2018.  OFAC first added these companies to the SDN List in April 2018 when it imposed sanctions on Oleg Deripaska due to his status as a senior Russian government official.  OFAC added these three companies to the SDN List because Deripaska was the majority owner of En+ Group (which, in turn, was the majority owner of both UC Rusal and ESE).  Under OFAC’s 50% ownership rule, these sanctions also extended to any subsidiaries in which En+ Group, UC Rusal or ESE held an ownership interest of 50% or greater. 
Continue Reading OFAC Announces Multiple Changes to Russia Related Sanctions