On Wednesday, July 26, the Departments of Commerce, Treasury, and Justice issued a Tri Seal Compliance Note detailing the voluntary self-disclosure of potential violations for export controls, sanctions, and other national security laws. The Compliance Note highlights the new changes made to the Department of Justice’s voluntary self-disclosure policy. The Note also provided an overview
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 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.
Summary of Changes in Russia/Belarus Export Controls and Sanctions Occurring From March 31, 2022 to April 22, 2022
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 21, 2022. As regular readers are aware, these restrictions are subject to frequent and sudden change. For summaries of previously imposed sanctions and coverage on
OFAC Imposes “First Tranche” of Russia Sanctions Aimed at Russian Banks and Oligarchs
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.
New Executive Order Authorizes Imposition of Additional Sanctions on the Government of Belarus and Certain Sectors of the Belarusian Economy
On August 9, 2021, President Biden issued Executive Order 14038 (the “EO”) which expanded the scope of the national emergency previously declared in EO 13405 of June 16, 2006. The EO imposes additional sanctions in response to conduct by the Government of Belarus (“GoB”) and the President Alyaksandr Lukashenka regime which the Biden Administration described
Biden Administration Imposes New Russia Sanctions and Establishes Framework for Future Expansion of Russian Sanctions Regime
Recently, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) sanctioned various individuals and entities connected to Russia’s technology sector and also expanded sanctions against dealings in Russian sovereign debt. In addition to these immediate actions, President Biden also issued a new Executive Order which will significantly expand OFAC’s authority to impose future sanctions
U.S. Treasury Department and U.S. Customs and Border Protection Announce 90-Day Duty Postponement due to COVID-19
On April 20, 2020, the Secretary of the Treasury and U.S. Customs and Border Protection (CBP) announced via the CBP Customs Service Messaging System (CSMS #4243171) that they would be postponing the deadline for payment for the deposit of certain estimated duties, taxes, and fees for importers who have experienced a “significant financial hardship” due