The latest on Russia sanctions from the International Trade and Supply Chain Team
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On March 30, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) modified and expanded a list of aircraft that have flown into Russia in apparent violation of the Export Administration Regulations (“EAR”).  We more thoroughly discussed the implications of this list – which was first published on March 18, 2022 – in our blog post here.  The updated list adds 73 additional Boeing-manufactured aircraft and modifies tail and/or serial number information for 13 aircraft previously listed on March 18, 2022.  The full list of owners/operators include Aeroflot, AirBridge Cargo, Aviastar-TU, Alrosa, Atran, Azur Air, Nordstar, Nordwind, Pegas Fly, Pobeda, Rossiya, Royal Flight, S7 Airlines, and Utair (FC Chelsea owner Roman Abramovich’s private Gulfstream jet is also on the list).
Continue Reading BIS Modifies and Expands List of Russian-Controlled Aircraft Subject to the EAR Known or Suspected to Have Violated the EAR

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.

 
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

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