Export Controls and Sanctions

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In coordination with other G7 countries, the United States announced another significant round of sanctions and export control restrictions on Russia on Sunday, May 8.  These include a new ban on the provision of certain services to Russia, new export controls, and sanctions on Russia’s media and financial sectors, and further additions to the…

Today, the Biden Administration announced a legislative proposal aimed at empowering the U.S. government to seize and forfeit property linked to Russian elites.  Specifically, the proposed system would enhance and streamline the seizure and forfeiture of Russian oligarch assets and provide for the liquidation and redistribution of proceeds to support Ukraine.  The announcement unveiled the…

Yesterday, the White House issued a proclamation banning Russian-affiliated vessels from entering U.S. ports in response to Russia’s continued aggression in Ukraine, effective April 28, 2022. Banned vessels include Russian-flagged vessels, vessels owned by Russian persons, and vessels that are Russian operated. The order authorizes the U.S. Department of Homeland Security to issue regulations to…

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 U.S. Office of Foreign Assets Control (OFAC) designated Transkapitalbank, a privately-held Russian commercial bank, and its subsidiary, Investtradebank, as Specially Designated Nationals (SDNs). OFAC imposed blocking sanctions on the banks due to their role in facilitating U.S. dollar payments for sanctioned clients and the development of systems designed to evade U.S. and EU…

Yesterday, the United Kingdom imposed additional restrictions on trade with Russia, including a luxury goods export ban, an iron and steel import ban, and asset freeze restrictions on over two-hundred Russian actors.  Notable sanctions targets include Eugene Tenenbaum and David Davidovich, prominent business associates of Roman Abramovich, whose frozen assets are estimated to be valued…

In a rule change that was effective April 8, 2022, but communicated on April 11, 2022 the Commerce Department’s Bureau of Industry and Security (BIS) expanded coverage of export controls on Russia and Belarus to include any item with an Export Control Classification Number (ECCN).  Prior controls applied to items in Commerce Control List (CCL)…

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…