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 sweeping export controls and sanctions on Belarus.  The export restrictions follows a similar template to the recent ban imposed against Russia.  Namely, the EU measure prohibits trade in listed dual-use goods and technology and broadly prohibits  trade of items that may contribute to Belarus’s military and technological enhancement.

The measure

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

Yesterday, the United Kingdom expanded export controls on shipments to Russia and imposed new sanctions on Russian and Belarusian parties in response to the ongoing conflict in Ukraine.  The latest measures impose a dual-use trading ban on Russia, asset freezes on specified parties, and financial sanctions on Sberbank.

Dual Use Export Controls

The UK updated

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,