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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

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

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

It has been almost three weeks since the U.S. and its allies began imposing serious new sanctions and export control restrictions on Russia and Belarus in response to Russia’s invasion of Ukraine.  This post summarizes the state of affairs as of Friday, March 11, 2022.

Please reach out to our team if you have any

On March 7, 2022, the Financial Crimes Enforcement Network (FinCEN) issued an alert advising financial institutions to be vigilant against attempts to evade recent U.S. sanctions imposed on Russia’s following that country’s invasion of Ukraine.

Sanctioned actors may try evade the reach of U.S. and allied sanctions measures by hiding behind non-sanctioned and third-country entities,

Over the last two weeks, the United States, European Union, and allied countries imposed a broad range of sanctions and export control restrictions on Russia and Belarus in response to Russia’s invasion of Ukraine.  Additional sanctions measures are likely in response to the very fluid situation in Ukraine.

This post summarizes the state of affairs

This week, the United States, European Union, and allied countries imposed a broad range of sanctions and export control restrictions on Russia in response to Russia’s invasion of Ukraine.  We expect Western countries to implement additional measures in the coming days and weeks in response to the very fluid situation in Ukraine.

This post summarizes

Today, the Treasury Department’s Office of Foreign Assets Control (OFAC) imposed blocking sanctions on 24 Belarusian individuals and entities for supporting or otherwise facilitating Russia’s actions in Ukraine, including two significant Belarusian banks, a series of defense companies, and government officials.

These individuals and entities have been added to OFAC’s List of Specially Designated Nationals