Last week, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) blacklisted 21 individuals and nine entities for various reasons, including involvement in the ongoing conflict in eastern Ukraine, connections to the Crimea region (which is subject to a complete U.S. embargo), and links to the Russian government. Several of the newly minted Specially Designated Nationals (SDNs), including Russian engineering company Technopromexport, were allegedly involved in diverting Siemens-made gas turbines to Crimea in potential violation of European Union sanctions rules. OFAC also added twelve subsidiaries of Surgutneftegaz to the Sectoral Sanctions Identification List, clarifying that the entities are subject to the energy-sector sanctions described in Directive 4 to E.O. 13662.
Continue Reading New OFAC designations signal continued U.S. sanctions pressure on Russia
U.S. Issues Enhanced Sanctions on Russian Energy Sector
As required under recent sanctions legislation, the U.S. Office of Foreign Assets Control (OFAC) recently issued an updated Directive 4 that will expand sectoral sanctions on the Russian energy industry.
The new rules, which apply to projects initiated on or after January 29, 2018, will bar persons subject to U.S. jurisdiction from providing goods, services, or technology in support of exploration or production for deepwater, Arctic offshore, or shale oil anywhere in the world if a party subject to Directive 4 sectoral sanctions has a 33 percent or more ownership interest or owns a majority of the voting interests in the project.
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Secondary Sanctions Targeting Russia’s Defense and Intelligence Sectors Move Closer to Implementation
Last Friday the State Department belatedly released a list of 39 Russian entities that operate as part of Russia’s defense and intelligence sectors (the full list is below). Congress required the Trump Administration to produce a list of such parties as part of the Countering America’s Adversaries Through Sanctions Act (CAATSA), which became law in August 2017. Under Section 231 of CAATSA, persons that engage in “significant” transactions with the designated firms could be subject to a menu of secondary sanctions starting on January 29, 2018.
Continue Reading Secondary Sanctions Targeting Russia’s Defense and Intelligence Sectors Move Closer to Implementation
U.S. Targets Chinese and Russians for North Korea Dealings
The Office of Foreign Assets Control (OFAC) designated 16 parties as Specially Designated Nationals (SDNs) today, effectively seizing their assets in the United States, blocking them from doing business with U.S. parties, and denying them access to the U.S. financial system. The designations mark the latest escalation of sanctions on North Korea and an
Russia Under Scrutiny
Earlier this month, the Office of the U.S. Trade Representative (“USTR”) published a notice seeking public comment and participation in a hearing on Russia’s implementation of its obligations under the World Trade Organization (“WTO”). Public comments, summaries of hearing testimony, and requests to appear at the hearing are due on September 22, 2017. The hearing will be held at USTR on September 28, 2017.
Written comments and testimony at the hearing will assist USTR in preparing its annual report to Congress on how Russia has done in meetings its WTO commitments. This will be USTR’s fifth such report to Congress pursuant to the Russia and Moldova Jackson-Vanik Repeal and Sergei Magnitsky Rule of Law Accountability Act of 2012, known as the Magnitsky Act. The Magnitsky Act marked the extension of permanent normal trade relations to goods and services from Russia and allowed the United States to recognize Russia as a new member of the WTO, which it had joined several months prior to the law’s enactment.
New Russia, Iran, and North Korea Sanctions Become Law
Today the President signed landmark legislation into law mandating new and enhanced sanctions on Russia, Iran, and North Korea. As noted in our prior posts, here and here, the law will tighten existing sanctions on those countries and provide the U.S. government with broader power to penalize companies under primary and secondary sanctions rules.
Congress Takes The Lead In Broad New Sanctions Against Russia
On June 15, 2017, the Senate overwhelmingly – by a vote of 98-2 – approved broad new sanctions against Russia in response to that country’s interference in the 2016 U.S. election and its ongoing aggression in Syria and Ukraine.
The legislation would make several big changes. First, the package would codify existing sanctions on Russia, which were imposed in the wake of the invasion of Crimea, into law. Codifying the sanctions would prevent the White House from unilaterally easing or lifting the sanctions, which the administration could do under current law without obtaining approval from Congress.
Continue Reading Congress Takes The Lead In Broad New Sanctions Against Russia