Category Archives: Russia

Key Takeaways:

• OFAC imposes restrictions on the importation of gold from the Russian Federation
• OFAC and the U.S. Department of State impose new sanctions on Russian entities and individuals with a focus on the Russian defense and aerospace industries
• The U.S. Department of Commerce’s Bureau of Industry and Security imposes additional export controls on entities identified as attempting to evade U.S. export controls and sanctions on Russia and issues a joint alert with FinCEN warning U.S.…

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Key Takeaways:

US Actions:

• The Bureau of Industry and Security (“BIS”) imposes new restrictions on the export of certain industrial EAR99 items to Russia
• OFAC extends expiration date for general licenses related to administrative transactions and issues general license authorizing the processing of pension payments to U.S. persons by Russian financial institutions
• OFAC adds Russian government officials, oligarchs, and mining companies to the SDN List,…

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Key Takeaways:

• The U.S. restricts the provision of accounting, trust and corporate formation, and management consulting services to Russia
• OFAC publishes general license authorizing certain IP-transactions prohibited by the Russian Harmful Foreign Activities Sanctions Regulations
• Three Russian state-run media television companies are added to the SDN List, along with a Russian state-owned bank and a state-controlled defense company
• BIS implements stricter export controls – only EAR99 items (with some limited exceptions) are now eligible for export from the U.S.…

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Key Takeaways:

• U.S. sanctions major Russian state-owned enterprises Alrosa (diamonds) and United Shipbuilding Corporation (defense sector)
• OFAC publishes new Russia-related general licenses, including a license authorizing certain transactions related to telecommunications
• “Fifth Wave” EU sanctions package restricts trade with Russia and imposes sanctions on 217 individuals and 18 entities

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I.    U.S. Actions

Following increased sanctions on Russian banks and a new Executive Order banning investment in the Russian Federation (reported by Foley Hoag here),… More

Key Takeaways:

• New Executive Order prohibits all new investment by U.S. persons in Russia
• U.S. imposes full asset freezing sanctions on Alfa-Bank and Sberbank, along with more Russian government officials and their family members, including the daughters of Russian President Vladimir Putin
• Sanctions target Russian cybercrime and ransomware

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I.    New Executive Order Bans U.S. Investment in Russia

On April 6,… More

Key Takeaways:

• U.S. imposes sanctions on Duma members, board members and executives of sanctioned Russian banks, and defense companies
• UK sanctions 65 individuals and entities, focusing on Russian oligarchs, financial institutions, and senior executives of state-owned enterprises
• OFAC issues new FAQ clarifying that gold transactions fall within the scope of existing Russia-related sanctions

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U.S. Sanctions

The U.S.… More

Key Takeaways:

• U.S., UK, and EU impose additional sanctions in response to Russia’s continued escalation of conflict in Ukraine
• U.S. imposes sanctions on human rights violators and senior Russian defense officials
• UK sanctions over 370 Russian individuals, including 51 oligarchs and their family members
• EU imposes investment and trade restrictions and sanctions Russian oligarchs, propagandists, state-owned entities, and defense sector entities

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On March 15,… More

Key Takeaways:

• New Executive Order prohibits certain imports and exports, and authorizes the Department of the Treasury to impose significant restrictions on U.S. investment in Russia
• Additional wave of sanctions targeting Russian “elites” close to President Vladimir Putin
• OFAC guidance clarifies that Russia-related sanctions prohibitions apply to cryptocurrency transactions

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On March 11, 2022, President Biden signed a new Russia-related Executive Order,… More

Key Takeaways:

• The Biden administration announces ban on import of Russian energy commodities and prohibition on new investment in the Russian energy sector
• New General License provides wind-down period until April 22, 2022 for certain energy imports from Russia pursuant to agreements entered into before March 8, 2022
• EU and UK expand their sanctions programs against Russia and Belarus, including additional sanctions on oligarchs
• FinCEN issued an alert to all financial institutions to be vigilant against efforts to evade the expansive sanctions and other restrictions imposed in connection with the invasion of Ukraine

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I.… More

Key Takeaways:

• U.S. imposes additional sanctions on Russian elites, along with their family members, companies, and personal vehicles
• Actions targeting the defense sector and Russian government-affiliated media outlets signal the expansion of U.S. sanctions to new industries
• SWIFT access to be denied to seven Russian banks on March 12, 2022
• New export controls target Belarus and further restrict export of items that use encryption to Russia and Belarus

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I.… More

Key Takeaways: 

• New Directive 4 prohibits transactions with Russian Central Bank, National Wealth Fund, and Ministry of Finance
• Full blocking sanctions on Russian Direct Investment Fund and affiliates
• Multi-lateral response to Russia’s invasion continues with unprecedented imposition of sanctions by Switzerland and Monaco

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On February 28, 2022, the U.S. government announced new sanctions on the Central Bank of Russia,… More

Key Takeaways: 

• The initial wave of sanctions targeted Russian banks and the financial industry plus individual “inner circle” elites, with more sanctions likely to follow in the coming weeks as events unfold.
• Broad restrictions on debt and equity transactions with certain entities in the Russian financial, energy, and infrastructure sectors.
• Expanded export controls, including foreign-direct product rule restrictions, new license requirements, and Entity List designations impact a wide range of exports to Russia.…

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Key Takeaways:

• The U.S., EU, and UK are coordinating a significant sanctions and export controls package to be implemented if Russia takes further action in Ukraine.
• Restrictions are likely to target key Russian industries including finance, energy, and defense and would be far more severe and far-reaching than past sanctions.
• New export controls could include restrictions on foreign-produced items made using U.S.-origin technology or software,…

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