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
Kelley Drye
EU Publishes Fifth Round of Sanctions on Russia
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…
U.S. Issues Telecommunications & Internet Communications General License for Russia
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…
U.S. Imposes Sanctions on Alrosa – World’s Largest Diamond Producer, Extends Sanctions on United Shipbuilding Corporation
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…
U.S. Imposes Temporary Denial Orders On Three Major Russian Airlines
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…
U.S. imposes embargo on separatist regions of Ukraine (UPDATED)
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…
Commerce Department Consolidates and Clarifies the Foreign-Made Direct Product Rules Amid Rising Tensions With Russia
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,…
U.S. Authorizes New Sanctions on Ethiopia and Updates ITAR Licensing Policy
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…
New Authority to Impose Sanctions in Connection with Russian Energy Pipelines
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…
OFAC Settlement with Payoneer Inc. Highlights Sanctions Expectations for Online Services
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…