On December 16, 2022, the U.S. Commerce Department’s Bureau of Industry and Security (“BIS”) published a rule adding 35 entities from China and one entity from Japan to the EntityContinue Reading BIS Adds 35 Chinese Entities to Entity List for Supporting China’s Military Modernization Efforts and Nine Russian Entities for Failure to Complete Satisfactory End-Use Checks
On December 15, 2022, the Office of Foreign Assets Control (“OFAC”) added 18 entities in Russia’s financial services sector to the Specially Designated Nationals and Blocked Persons List (“SDN List”).Continue Reading OFAC Continues to Take Aim at Russia’s Financial Sector with More SDN Designations
BIS Adds 24 New Entities and Removes One from Entity List
On December 8, 2022, the Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a notice in the…Continue Reading BIS Adds 24 New Entities and Removes One from Entity List and Extends Deadline for Comments to New Semiconductor Rules
On June 28, 2022, the Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) and the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a Joint Alert urging financial institutions to be vigilant against efforts by individuals or entities to evade BIS export controls implemented in connection with the Russian Federation’s further invasion of Ukraine. After providing an overview of recent BIS actions in response to Russia’s invasion of Ukraine, the Joint Alert identifies commodities that present “special concern because of their potential diversion to and end use by Russia and Belarus to further their military and defense capabilities,” all of which require a BIS license prior to export or reexport to Russia and Belarus.
Continue Reading U.S. Departments of Treasury and State Expand Sanctions To Restrict Russia’s Access to Services and Economics and Combat Evasion and Backfill Activities
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 March 18, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) publicly identified certain commercial and private aircraft that have entered Russia in likely violation of…
Continue Reading BIS Signals Aggressive Enforcement Approach to Russia-Related EAR Violations
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.
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.