The US continues to ramp up sanctions pressure on Russia, now emphasizing Russian efforts to evade US export controls and obligations of financial institutions to police Russian efforts at sanctions and export controls evasion. Recent US actions include:

..Extending the general license for energy-related transactions involving seven Russian banks (and their subsidiaries) until December 5, 2022, the same date when the new EU partial Russian oil ban comes into full effect.

..Adding 36 entities to the Commerce Department Entity List (export/reexport ban), including several Chinese electronics companies, for reportedly continuing to contract to supply sanctioned Russian parties Russian entity listed and sanctioned parties after Russia’s continued invasion of Ukraine.

..Treasury (FinCen) and Commerce (Bureau of Industry and Security) issued a joint alert to financial institutions, advising them to be vigilant against efforts to evade US export controls applicable to Russia.