The latest on Russia sanctions from the International Trade and Supply Chain Team
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On June 2, 2022, the Office of Foreign Assets Control (OFAC) added new Russian vessels and aircraft used by Russian elites, new top Russian government officials, and their companies and operations to the Specially Designated Nationals (SDN) List for aiding in the continued war effort by Russia against Ukraine.  Notably, these designations include more Russian government officials and oligarchs, and two of the largest mining companies in Russia, Severstal PJSC (Severstal) and Nord Gold PLC (Nord Gold).  This means that U.S. persons cannot engage in any transactions with Severstal or Nord Gold unless authorized by a license.
Continue Reading OFAC and State Department Designate Severstal, Nord Gold and Additional Russians as SDNs

On May 8, 2022 the U.S. Department of the Treasury’s (“Treasury”) Office of Foreign Assets Control (“OFAC”) further escalated U.S. sanctions against the Russian Federation (“Russia”) by issuing two Determinations,…
Continue Reading OFAC Issues New Sanctions Prohibiting Certain Accounting, Auditing, Corporate Formation and Management Services to Persons in Russia Effective June 7, 2022; And Additional Bank Designations and General Licenses

This blog post covers several new sanctions and export controls that the U.S. government imposed on Russia and Belarus in the time period occurring between March 31, 2022 and April…
Continue Reading Summary of Changes in Russia/Belarus Export Controls and Sanctions Occurring From March 31, 2022 to April 22, 2022

On March 24, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) updated the Specially Designated Nationals and Blocked Persons List (“SDN List”) with hundreds of…
Continue Reading OFAC Announces Hundreds of New SDN Designations Targeting Russia’s Duma, Defense Sector and Bank Officials; Issues New General Licenses

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

Russia has amassed more than 100,000 troops at the Ukrainian border, leading the White House to issue a warning on January 25 that the U.S. is “prepared to implement sanctions…
Continue Reading U.S. Government Signals that Increased Sanctions and Export Controls Will Likely Follow if Russia Invades Ukraine