Following the death of political activist Aleksey Navalny and to mark the second anniversary of Russia’s invasion of Ukraine, the United States, EU and UK adopted a series of amendments to their respective economic sanctions...more
On December 22, 2023, President Biden issued a new Russia-related Executive Order (“EO”) targeting foreign financial institutions (“FFIs”) that support Russia’s military-industrial base. The new EO allows the U.S. government...more
On May 19, 2023, the US Department of Treasury, State, and Commerce imposed the most significant tranche of sanctions and export control measures in several months. The measures included (i) new designations on the Specially...more
On 9 September 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published “Preliminary Guidance on Implementation of a Maritime Services Policy and Related Price Exception for Seaborne...more
The U.S. Government has imposed additional punitive measures against Russia in response to Russia’s actions in Ukraine. The new measures include a prohibition on imports of Russian gold into the United States, new SDN and...more
7/5/2022
/ Blocking Sanctions ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Controls ,
FinCEN ,
Foreign Policy ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
State-Owned Enterprises ,
Supply Chain ,
Ukraine
On 2 June 2022, the U.S. Commerce Department’s Bureau of Industry and Security (“BIS”) issued two final rules, effective on the same day, that revised the Export Administration Regulations (“EAR”) pertaining to the U.S.’s...more
The U.S. Bureau of Industry and Security (“BIS”) has expanded export controls relating to Russia. The final rule imposes license requirements for exports, reexports and transfers to/within Russia on several items with...more
On February 24, 2022, the US Government imposed severe economic sanctions and export controls on Russia. The restrictions consist of two parts: 1) significant financial sanctions on a range of Russian financial institutions...more
There are two parallel sanctions processes unfolding in Washington, D.C. – one from the Biden administration and the other from the U.S. Congress. Regardless of what approach the government takes, we do not expect the life...more
On 15 April 2021, the U.S. Government announced a number of new sanctions measures against Russia, targeting a variety of “harmful foreign activities” contrary to U.S. foreign policy. ...more
4/21/2021
/ Biden Administration ,
Crimea ,
Critical Infrastructure Sectors ,
Defense Sector ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
Foreign Policy ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
SolarWinds ,
Sovereign Debt ,
State-Owned Enterprises ,
Technology Contracts
On 26 August 2020 the United States Department of Commerce's Bureau of Industry and Security (BIS) expanded the Entity List, restricting certain transactions with 60 entities under a total of 61 entries to the Entity List....more
8/28/2020
/ China ,
Entity List ,
Export Controls ,
Exports ,
France ,
Hong Kong ,
Indonesia ,
Infrastructure ,
Malaysia ,
Oman ,
Pakistan ,
Russia ,
Switzerland ,
Telecommunications ,
United Arab Emirates (UAE)
On 28 April the U.S. Commerce Department, Bureau of Industry and Security published two final rules and a proposed rule amending the Export Administration Regulations that will further restrict and regulate transactions...more
Three important regulatory developments were published yesterday in the Federal Register by the Commerce Department’s Bureau of Industry and Security...more
On 24 February 2020 the Bureau of Industry and Security (BIS) of the U.S. Department of Commerce published a final rule amending the Export Administration Regulations (EAR) and imposing additional export licensing...more
2/28/2020
/ Aircraft ,
Biological-Weapons ,
Bureau of Industry and Security (BIS) ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Foreign Relations ,
Licensing Rules ,
National Security ,
Nuclear Weapons ,
Russia ,
Software ,
U.S. Commerce Department ,
Vessels ,
Yemen
On 2 August the United States announced that it will impose a second round of sanctions on Russia pursuant to the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (CBW Act) (22 U.S.C. § 5601 et...more
On 19 December 2018, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) submitted a notification to Congress that it plans to terminate sanctions on three major companies originally designated for...more
The past two weeks have entailed a flurry of sanctions developments related to Russia, including the issuance of a new executive order, and the designation of a number of entities by the U.S. Department of the Treasury's...more
On 8 August, the U.S. Department of State announced that new sanctions would be imposed on Russia pursuant to the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (CBW Act). The sanctions relate to...more
Today, the Trump Administration designated multiple Russian targets, including several wealthy individuals and their companies, as Specially Designated Nationals (SDNs). These designations of major companies represent the...more
On Monday, 29 January, the U.S. Treasury Department submitted an unclassified report to Congress concerning significant senior political figures and oligarchs in the Russian Federation and Russian parastatal entities.
...more
On 27 October, the U.S. Department of State published guidance with respect to Russia’s Defense and Intelligence sectors under section 231 of the Countering America’s Adversaries The Sanctions Act (CAATSA). Section 231...more
On Tuesday, July 25, the U.S. House of Representatives passed H.R. 3364, the Countering America’s Adversaries Through Sanctions Act by a vote of 419-3.
There is some uncertainty, but the legislation is expected to be...more
Last week, the U.S. Senate acted to pass both new Iran and Russia sanctions by large bipartisan margins. The House of Representatives has not yet acted on either piece of legislation. We anticipate that Congress will...more
6/21/2017
/ Cybersecurity ,
Human Rights ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Mining ,
Nuclear Weapons ,
Pending Legislation ,
Railways ,
Russia ,
Shipping ,
Terrorist Threats
While much attention has been focused on the Trump Administration's recent actions targeting imports of metals, lumber, and other commodities, the Administration has also steadily ramped up its activities in the trade...more
5/1/2017
/ Chemical Weapons ,
Executive Orders ,
Exports ,
Exxon Mobil ,
Imports ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
National Security ,
Offshore Drilling ,
Oil & Gas ,
Russia ,
Syria ,
Trump Administration ,
U.S. Treasury