Kelley Drye

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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…

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…

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…

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…

This post was updated on February 25, 2022 after the Department of Commerce amended the Export Administration Regulations (EAR) to impose additional elements of the embargo.

OFAC Provisions

On February 21, 2022 President Biden issued an Executive Order (E.O.) imposing an embargo on the “so-called Donetsk People’s Republic (DNR) and Luhansk People’s Republic (LNR)” following…

On February 3, 2022, the Commerce Department published a final rule amending the Export Administration Regulations (“EAR”) to clarify the scope of the foreign-direct product rule (“FDPR”).  The FDPR expands the jurisdiction of the EAR, the principal set of regulations that control the export, re-export, and transfers of dual use U.S.-origin items.

Under the FDPR,…

Last week, the Biden administration issued a new Executive Order (“E.O.”) that authorizes “menu-based” sanctions on persons determined to be responsible for or complicit in the ongoing crisis in northern Ethiopia, and announced a policy of denial for export licenses of military equipment to Ethiopia.  The two actions are aimed to stop the escalating conflict…

On August 20, 2021, President Biden signed a new Executive Order to further implement sanctions provided under the Protecting Europe’s Energy Security Act (“PEESA”) of 2019.  PEESA, which was enacted earlier this year, requires the State Department to issue a periodic report naming parties involved in the construction certain Russian energy export pipelines.  Last week’s…

On July 23, 2021, the Office of Foreign Assets Control (“OFAC”) announced a settlement agreement with online money transmitter Payoneer Inc. (“Payoneer” or the “company”) for processing online transactions on behalf of persons in sanctioned jurisdictions and persons on OFAC’s  Specially Designated Nationals (“SDN”) List.  The case is the latest in a string of OFAC…