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Today, the Biden Administration issued a new Executive Order (E.O.) banning imports of Russian-origin energy into the United States and prohibiting new investments in the Russian energy sector.  Although the United States imports relatively little energy from Russia, the move is seen as an important measure to reduce Russia’s access to foreign currency.  The investment

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

Yesterday, the Commerce Department’s Bureau of Industry and Security (BIS) issued a final rule restricting the export of critical oil refining equipment to Russia and tightening license requirements for exports to the Russian oil and gas industry.

The final rule makes two key changes to current sanctions on the Russian energy sector.  First, the rule

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,