Export Controls and Sanctions

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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…

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…

Today, by overwhelming margins, Congress passed two pieces of legislation to further punish Russia for its invasion of Ukraine. The bipartisan bills suspend Permanent Normal Trade Relations (PNTR) with Russia and Belarus and codify President Biden’s recent Executive Order banning Russian energy imports. The bills now head to the President’s desk and are expected to…

Today, the United States imposed broad new sanctions on Russia in response to the continuing conflict in Ukraine.  The new measures include full blocking sanctions on Sberbank and Alfa-Bank, two of the largest banks in Russia, a ban on new investment on any sector of the Russian economy, and blocking sanctions on additional Russian elites. …

Today, the United Kingdom announced its next package of sanctions on Russia.

The measures, elements of which were implemented today, are aimed at reducing dependency on Russian energy, and further degrading Russia’s economy and capabilities.  In today’s action, the UK expanded its financial sanctions to subject Sberbank, the Credit Bank of Moscow, and Russian oligarchs…

On Friday, the Commerce Department’s Bureau of Industry and Security (BIS) added 120 parties operating in the Russian and Belarusian aerospace, maritime, and defense sectors to the Entity List.  BIS designated the parties for attempting to procure items subject to the Export Administration Regulations (EAR) for the Russian and Belarusian militaries and for their military…

Today, the United States imposed sanctions on Russian technology companies and a network of companies involved in procuring goods for the Russian Intelligence Services.  The Treasury Department also issued a determination authorizing the Office of Foreign Assets Control (OFAC) to impose sanctions on companies and individuals that it determines operate in the aerospace, electronics, or…

Today, the United Kingdom expanded sanctions on Russia by imposing asset freeze restrictions on 59 Russian and six Belarusian actors.  The measures target key strategic industries in Russia, and include large banks, defense companies, and Russian elites.

Of note, the following Russian banks and companies have been added to the U.K.’s consolidated asset freeze list:…