In coordination with other G7 countries, the United States announced another significant round of sanctions and export control restrictions on Russia on Sunday, May 8.  These include a new ban on the provision of certain services to Russia, new export controls, and sanctions on Russia’s media and financial sectors, and further additions to the Office... Continue Reading

Today, the Biden Administration announced a legislative proposal aimed at empowering the U.S. government to seize and forfeit property linked to Russian elites.  Specifically, the proposed system would enhance and streamline the seizure and forfeiture of Russian oligarch assets and provide for the liquidation and redistribution of proceeds to support Ukraine.  The announcement unveiled the... Continue Reading

Yesterday, the White House issued a proclamation banning Russian-affiliated vessels from entering U.S. ports in response to Russia’s continued aggression in Ukraine, effective April 28, 2022. Banned vessels include Russian-flagged vessels, vessels owned by Russian persons, and vessels that are Russian operated. The order authorizes the U.S. Department of Homeland Security to issue regulations to... Continue Reading

On April 19, 2022, the Office of Foreign Assets Control (OFAC) issued a fact sheet with guidance on various humanitarian general licenses that authorize activities otherwise prohibited by U.S. sanctions, and respond to the threat Russia’s war in Ukraine poses to global food and energy supply chains.  The fact sheet provides consolidated guidance to non-governmental organizations,... Continue Reading

Today, the U.S. Office of Foreign Assets Control (OFAC) designated Transkapitalbank, a privately-held Russian commercial bank, and its subsidiary, Investtradebank, as Specially Designated Nationals (SDNs). OFAC imposed blocking sanctions on the banks due to their role in facilitating U.S. dollar payments for sanctioned clients and the development of systems designed to evade U.S. and EU... Continue Reading

Yesterday, the United Kingdom imposed additional restrictions on trade with Russia, including a luxury goods export ban, an iron and steel import ban, and asset freeze restrictions on over two-hundred Russian actors.  Notable sanctions targets include Eugene Tenenbaum and David Davidovich, prominent business associates of Roman Abramovich, whose frozen assets are estimated to be valued... Continue Reading

In a rule change that was effective April 8, 2022, but communicated on April 11, 2022 the Commerce Department’s Bureau of Industry and Security (BIS) expanded coverage of export controls on Russia and Belarus to include any item with an Export Control Classification Number (ECCN).  Prior controls applied to items in Commerce Control List (CCL)... Continue Reading

Today, the European Union published its fifth major round of sanctions on Russia and Belarus.  The sanctions package includes a full transaction ban on four major Russian banks, port and transportation sanctions, import bans on coal, wood, cement, seafood, and liquor, an export ban on jet fuel and certain sensitive goods, additional asset freezes, and... Continue Reading

On April 7, the U.S. Office of Foreign Assets Control (OFAC) issued a new General License No. 25 (GL25) authorizing certain transactions ordinarily incident to telecommunications and the exchange of communications over the internet in Russia. GL25 authorizes U.S. persons to engage in transactions that are ordinarily incident and necessary to the to the receipt or transmission... Continue Reading

Yesterday, the U.S. Office of Foreign Assets Control (OFAC) added Public Joint Stock Company Alrosa (Alrosa) to the List of Specially Designated Nationals (SDN List), subjecting the company and its majority-owned subsidiaries to full U.S. blocking sanctions.  According to OFAC, Alrosa is the world’s largest diamond mining company and is responsible for 90 percent of Russia’s diamond mining... Continue Reading

Yesterday, the Commerce Department’s Bureau of Industry and Security (“BIS”) issued temporary denial orders (“TDOs” or “orders”) on three Russian airlines – Aeroflot, Azur Air, and UTair – effectively cutting them off from U.S. exports, U.S.-origin items, and items manufactured abroad that are subject to the Export Administration Regulations (EAR).  The orders represent the agency’s... Continue Reading

Today, by overwhelming margins, Congress passed two pieces of legislation to further punish Russia for its invasion of Ukraine. The bipartisan bills suspend Permanent Normal Trade Relations (PNTR) with Russia and Belarus and codify President Biden’s recent Executive Order banning Russian energy imports. The bills now head to the President’s desk and are expected to... Continue Reading

Today, the United States imposed broad new sanctions on Russia in response to the continuing conflict in Ukraine.  The new measures include full blocking sanctions on Sberbank and Alfa-Bank, two of the largest banks in Russia, a ban on new investment on any sector of the Russian economy, and blocking sanctions on additional Russian elites. ... Continue Reading

Today, the United Kingdom announced its next package of sanctions on Russia. The measures, elements of which were implemented today, are aimed at reducing dependency on Russian energy, and further degrading Russia’s economy and capabilities.  In today’s action, the UK expanded its financial sanctions to subject Sberbank, the Credit Bank of Moscow, and Russian oligarchs... Continue Reading

On Friday, the Commerce Department’s Bureau of Industry and Security (BIS) added 120 parties operating in the Russian and Belarusian aerospace, maritime, and defense sectors to the Entity List.  BIS designated the parties for attempting to procure items subject to the Export Administration Regulations (EAR) for the Russian and Belarusian militaries and for their military... Continue Reading

Today, the United States imposed sanctions on Russian technology companies and a network of companies involved in procuring goods for the Russian Intelligence Services.  The Treasury Department also issued a determination authorizing the Office of Foreign Assets Control (OFAC) to impose sanctions on companies and individuals that it determines operate in the aerospace, electronics, or marine sectors of the Russian economy.... Continue Reading

Today, the United Kingdom expanded sanctions on Russia by imposing asset freeze restrictions on 59 Russian and six Belarusian actors.  The measures target key strategic industries in Russia, and include large banks, defense companies, and Russian elites. Of note, the following Russian banks and companies have been added to the U.K.’s consolidated asset freeze list:... Continue Reading

In coordination with G7 countries and the European Union, the United States imposed additional sanctions on Russia today, targeting Russian defense and aerospace companies, the Russian Duma, and the CEO of Sberbank, among others.  The White House also announced that the United States, G7, and EU are launching an anti-evasion initiative to coordinate responses to measures intended to undercut... Continue Reading

The pace of new Russia sanctions matters slowed this week, with most of the action coming out of the European Union and United Kingdom.  New measures this week included bans on imports of steel and iron products, exports of luxury goods, investments in the Russian energy sector, and dealings with oligarchs and Russian state-owned enterprises. ... Continue Reading

Today, the European Union imposed another round of significant sanctions and trade controls on Russia in response to the crisis in Ukraine.  In addition to new asset freeze sanctions, the EU implemented a series of new trade restrictions on dealings with the Russian economy, including an import ban on Russian iron and steel products, a ban on exports... Continue Reading