Export Controls and Sanctions

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Last Friday, on the anniversary of the Ukraine invasion, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) took significant action by imposing sanctions against the Russian economy, targeting Russia’s financial services sector, sanctions evasion networks, military supply chains, and metals and mining sector.  The U.S. Department of Commerce’s Bureau of Industry and…

The Office of Foreign Assets Control (“OFAC”) recently announced a settlement agreement with Danfoss A/S (“Danfoss” or “the company”) in response to allegations that Danfoss directed its customers in Iran, Syria, and Sudan to make payments through third-party agents to Danfoss’s bank account at the branch of a U.S. financial institution located in the United…

Today, the Office of Foreign Assets Control (“OFAC”) added Russian oligarch Vladimir Potanin along with several of his companies to the Specially Designated Nationals (“SDN”) List.  OFAC’s action specifically targets Mr. Potanin, Interros, an investment holding company controlled by Mr. Potanin, and Rosbank, a major Russian bank owned by Interros.  U.S. persons are prohibited from…

As part of a comprehensive streamlining effort, the U.S. State Department’s Directorate of Defense Trade Controls (DDTC) issued an interim final rule that reorganizes and restructures Part 120 of the International Traffic in Arms Regulations (ITAR).  This action marks the initial stage of the DDTC’s effort to restructure and consolidate the ITAR through a series…

Yesterday, the European Union implemented its eighth round of sanctions on Russia in response to Russia’s claimed annexation of Ukrainian territory.  This latest package includes expanded import and export restrictions, an initial implementation of an EU price cap on the transport of Russian seaborne oil, an expansion of restrictions on non-government controlled regions of Ukraine…

Today, the U.S. Treasury Department and Commerce Department imposed new sanctions on Russia and Belarus as part of the G-7’s collective response to Russia’s claimed annexation of additional Ukraine territory.  The new sanctions target supporters of Russia’s military and defense sectors in Russia, Belarus, and third countries.

The Treasury Department’s Office of Foreign Assets Control…

Today, the U.S. Treasury, State, and Commerce Departments announced new sanctions and export control restrictions on Russia and Belarus, targeting parties in and activities related to the technology, quantum computing, finance, and advanced manufacturing sectors.  The Commerce Department’s Bureau of Industry and Security (BIS), in particular, expanded and updated a number of Russia-…

On September 8, the U.S. Office of Foreign Assets Control (OFAC) extended a general license authorizing certain administrative transactions involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation. The new General License 13B authorizes U.S. persons and entities owned…

Yesterday, the U.S. Bureau of Industry and Security (BIS) issued an interim rule imposing new export controls on four emerging and foundational technologies.  The new rules control two substrates of ultra-wide gap semiconductors; Electric Computer-Aided Design (ECAD) software specially designed for the development of integrated circuits with Gate-All-Around Field-Effect Transistor (GAAFET) structure; and Pressure Gain…

Today, the United States imposed another round of sanctions on Russia, targeting Russian elites, universities, and technological institutions.

Blocking Sanctions

The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) added the following notable Russian elites to the List of Specially Designated Nationals (SDN), subjecting them to full U.S. blocking sanctions:

  • Andrey Grigoryevich Guryev, Russian

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