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Yesterday, the Office of Foreign Assets Control (OFAC) issued guidance and general licenses clarifying the intended scope of the Directive 4 sanctions imposed on the Russian Central Bank, National Wealth Fund, and Ministry of Finance (Directive 4 entities).   As outlined in our earlier post, Directive 4 prohibits any transactions involving a Directive 4 entity, including

Today, the United States followed the European Union and United Kingdom in imposing sanctions on 19 Russian oligarchs and their family members and close associates.

Alisher Usmanov, an oligarch with vast holdings, was among those added to the U.S. List of Specially Designated Nationals (SDN List).  However, U.S. persons are authorized to continue to engage

March 4, 2022 Update: This post was updated after BIS published new export controls on oil and gas equipment and Entity List sanctions on firms related to the Russian defense industry.

Today, the United States announced another round of significant sanctions and export control restrictions on Russia and Belarus in response to the deteriorating situation

Today, the European Union imposed a ban on the provision of specialized financial messaging services, including SWIFT interbank messaging network services, to seven Russian banks.  The removal goes into effect March 12, 2022 and applies to the listed banks as well as entities directly or indirectly owned 50 percent or more by the banks.  All

The United States, European Union, and other G7 members imposed coordinated sanctions on Russia’s Central Bank today in a move that is designed to have a significant and sustained impact on the Russian economy by limiting Russia’s ability to sell foreign currency reserves and support the ruble.  The bloc had announced an agreement to impose

Today, the European Union announced that it would close EU airspace to all Russian-owned, Russian registered, or Russian-controlled aircraft, including private aircraft owned by the Russian elite.  The bloc’s move follows similar measures adopted by a growing number of Member States in recent days.

The EU will also impose sanctions on Russia Today and Sputnik,

Today, the United States, European Union, and allies issued a joint statement pledging additional sanctions on Russia in response to the escalating conflict in Ukraine.  While the details remain to be determined, the countries pledged new sanctions that will cut off certain Russian banks from the SWIFT interbank messaging system and sanctions that will restrict certain transactions by the Russian Central Bank.  The signatories also indicated that they will launch a transatlantic task force dedicated to identifying and freezing the assets of sanctioned parties.

The White House separately announced yesterday that the Russian Direct Investment Fund (RDIF) would be subject to full U.S. blocking sanctions.  The RDIF operates as a sovereign wealth fund and holds stakes in an array of businesses in Russia.

The sanctions landscape continues to rapidly evolve.  Companies with exposure to the Russian market should continue to monitor these developments.

Feb. 27, 2022 Update: Japan will also adopt these measures.

The full joint statement is below the break.

Continue Reading Western countries pledge sanctions related to SWIFT & Russia’s Central Bank

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

As part of a package of new sanctions on Russia that are effective February 24, 2022, the United States imposed a series of significant new export control measures on exports of many products, software and technology to Russia.  The Bureau of Industry & Security (BIS), the bureau at the Commerce Department that administers U.S. “dual

Today, the United States imposed a significant package of sanctions and export control restrictions on Russia following the escalating hostilities in Ukraine.  The European Union, United Kingdom, and allied countries have or are expected to impose similar, coordinated measures in the coming days.

This post provides an overview of the new U.S. sanctions measures.