The measure also harmonizes Russia sanctions rules with allies, and intensifies penalties against Iran -
The National Security Act, 2024 (Pub. L No 118-50) was enacted on April 24, 2024. In addition to the Act’s provisions...more
4/29/2024
/ China ,
EU ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Direct Product Rule ,
Iran ,
National Security ,
Regulatory Agenda ,
Regulatory Reform ,
Russia ,
Sanction Violations ,
Statute of Limitations ,
Trade Policy ,
UK
Contemporaneous with the European Union’s adoption of its 13th package of Russia sanctions, on February 23, 2024, the United States imposed sanctions against nearly 500 targets in continued response to Russia’s aggression...more
2/27/2024
/ Biden Administration ,
Defense Sector ,
Economic Sanctions ,
Executive Orders ,
Federal Procurement Systems ,
Financial Institutions ,
Financial Transactions ,
FinTech ,
Foreign Policy ,
General Licenses ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Payment Systems ,
Russia ,
Russian Military Procurement ,
SDN List ,
Ukraine ,
US State Departments
On May 19, 2023, the Biden Administration along with leaders of the Group of Seven (G7), unveiled a new package of sanctions. The G7 leaders released a joint statement reaffirming their commitment to offer “the financial,...more
6/6/2023
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Defense Sector ,
Economic Sanctions ,
Energy Sector ,
Entity List ,
Evasion ,
Executive Orders ,
Export Controls ,
Foreign Policy ,
G7 ,
General Licenses ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Prohibited Transactions ,
Russia ,
SDN List ,
Third-Party ,
U.S. Commerce Department ,
Ukraine
In recognition of the one-year anniversary of Russia’s invasion of Ukraine, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) and US Department of Commerce’s Bureau of Industry and Security (BIS)...more
3/6/2023
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Embargo ,
EU ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Financial Transactions ,
Foreign Policy ,
Foreign Relations ,
Foreign Trade Regulations ,
General Licenses ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Oil Prices ,
Petroleum ,
Russia ,
SDN List ,
Switzerland ,
Ukraine
On February 5, 2023, the G7 announced that the “price cap” on western-backed seaborne trades of Russian-origin petroleum products to third countries would be set at $45 per barrel ($45/bbl) for Discount to Crude petroleum...more
2/27/2023
/ EU ,
Exports ,
G7 ,
Goods or Services ,
Imports ,
Maritime Transport ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Oil Prices ,
Petroleum ,
Russia ,
Sanction Violations ,
Shipping ,
Suppliers ,
Supply Contracts ,
Ukraine
Oil price cap -
The oil price cap has been co-ordinated by the G7 in order to make EU, UK and US services (including (re)insurance) available to third country importers and exporters as long as the price paid for...more
12/12/2022
/ Asset Freeze ,
Belarus ,
Belarus Sanctions ,
Biden Administration ,
Crude Oil ,
Economic Sanctions ,
EU ,
Export Controls ,
Exports ,
G7 ,
General Licenses ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Oil Prices ,
Russia ,
SDN List ,
Switzerland ,
Third Country Entities (TCEs) ,
UK ,
Ukraine
The Office of Foreign Assets Control (OFAC) of the US Treasury Department has issued its eagerly awaited guidance on the mechanisms of its “maritime services” policy and “price cap exception” for the global transport of...more
Recently, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) has taken additional actions against Russia in response to its continued invasion of Ukraine. Specifically, OFAC:
..Issued guidance...more
10/31/2022
/ Asset Freeze ,
Belarus ,
Blocked Entities ,
Blocked Person ,
Economic Sanctions ,
EU ,
Export Controls ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Switzerland ,
Trade Restrictions ,
UK ,
Ukraine
Recently, the Biden Administration adopted additional sanctions in response to Russia’s attempts to annex parts of sovereign Ukrainian territory, including the designation of 14 persons in Russia’s military industrial...more
10/13/2022
/ Belarus ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Military Conflict ,
Military End Use ,
New Guidance ,
Russia ,
Third Country Entities (TCEs) ,
U.S. Commerce Department ,
Ukraine
Over the past few weeks, the Office of Foreign Assets Control (OFAC) of the US Department of the Treasury ramped up sanctions pressure against Russia with the announcement of a new ban on certain services in seaborne Russian...more
9/23/2022
/ Asset Freeze ,
Belarus ,
Belarus Sanctions ,
Blocked Entities ,
Blocked Person ,
Economic Sanctions ,
Export Controls ,
General Licenses ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
Ukraine
As a follow up to our alert of September 7th regarding the G7 proposal to implement a price cap with respect to seaborne Russian-origin crude oil and petroleum products, the Office of Foreign Assets Control (OFAC)...more
9/13/2022
/ Crude Oil ,
Economic Sanctions ,
Embargo ,
EU ,
Maritime Transport ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Oil Prices ,
Recordkeeping Requirements ,
Russia ,
Safe Harbors ,
Shipping
On September 2, 2022, the G7 Finance Ministers issued a statement confirming their intention to implement a price cap with respect to Russian-origin crude oil and petroleum products in response to Russia’s continued invasion...more
9/8/2022
/ Crude Oil ,
Economic Sanctions ,
EU ,
G7 ,
Importers ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Pipelines ,
Pricing ,
Russia ,
Ukraine
Over the past few weeks, the US Department of Treasury Office of Foreign Assets Control (OFAC) took various actions in response to Russia’s continued invasion in Ukraine:
..updated the Specially Designated Nationals and...more
8/17/2022
/ Asset Freeze ,
Belarus ,
Belarus Sanctions ,
Blocked Entities ,
Blocked Person ,
Economic Sanctions ,
Entity List ,
Export Controls ,
General Licenses ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
SDN List ,
Ukraine
Over the past few weeks, the US Department of the Treasury Office of Foreign Assets Control (OFAC) took additional actions in response to Russia’s continued invasion of Ukraine:
..Removed Kazakh subsidiary of Alfa Bank,...more
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...more
7/6/2022
/ Asset Freeze ,
Belarus ,
Belarus Sanctions ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Entity List ,
EU ,
Export Controls ,
Exports ,
FinCEN ,
Foreign Relations ,
General Licenses ,
Military Conflict ,
Oil & Gas ,
Russia ,
Switzerland ,
Trade Restrictions ,
UK ,
Ukraine
Following the invasion of Ukraine by Russia, the UK, EU and US have all responded by announcing significant sanctions in respect of Russia and Belarus.
This briefing summarises the key developments since 25 April 2022 and...more
Asset Freezes -
On 13 and 14 April 2022, the UK imposed asset freezes with respect to 208 individuals. This included alleged separatists, oligarchs, close associates and employees of oligarchs and individuals who have...more
After reports of humanitarian atrocities and further details of the continued Russian aggression in Ukraine emerged over the weekend, the United States and its allies responded with further sanctions and export controls. “The...more
During the past week, the US continued to strengthen its sanctions against Russia as Russia continued its invasion of Ukraine.
..BIS issued a final rule clarifying which luxury goods are subject to the ban on exports to...more
3/28/2022
/ Asset Freeze ,
Belarus ,
Economic Sanctions ,
EU ,
Export Controls ,
Exports ,
General Licenses ,
Imports ,
Russia ,
Trade Restrictions ,
UK ,
Ukraine
Following the invasion of Ukraine by Russia, the UK, EU and US have all responded by announcing significant sanctions in respect of Russia and Belarus.
The sanctions landscape has been changing at a fast pace and further...more
3/23/2022
/ Asset Freeze ,
Belarus ,
Blocked Entities ,
Blocked Person ,
Economic Sanctions ,
Entity List ,
EU ,
Export Controls ,
Foreign Relations ,
General Licenses ,
Russia ,
SDN List ,
Switzerland ,
UK ,
Ukraine
On March 7, 2022, the Financial Crimes Enforcement Network (FinCEN) issued an alert calling on financial institutions to be “vigilant” in guarding against attempts to evade the recent imposition of expanded Russia sanctions....more
3/21/2022
/ Anti-Money Laundering ,
Compliance ,
Economic Sanctions ,
Financial Institutions ,
FinCEN ,
Office of Foreign Assets Control (OFAC) ,
Reporting Requirements ,
Risk Management ,
Russia ,
Terrorist Financing Regulations ,
Virtual Currency
In the latest action to expand sanctions against Russia in response to its invasion of Ukraine, on March 8, 2022, President Biden announced in a televised speech a ban on imports of Russian oil, natural gas, and coal into the...more
3/11/2022
/ Biden Administration ,
Economic Sanctions ,
Executive Orders ,
Foreign Relations ,
General Licenses ,
Imports ,
Magnitsky Act ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
Tariffs ,
WTO
While the Biden Administration desires a “stable and predictable” relationship with Russia, it has now made it clear that it will take “actions to impose costs on Russia for actions by its government and intelligence services...more
4/22/2021
/ Biden Administration ,
Blocked Entities ,
Blocked Person ,
Blocking Sanctions ,
Crimea ,
Economic Sanctions ,
Executive Orders ,
Foreign Policy ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia
On December 14, 2020, the United States (US) imposed sanctions on Turkey pursuant to Countering America’s Adversaries Through Sanctions Act (CAATSA) for “knowingly engaging in a significant transaction with Rosoboronexport...more
Today, under its Venezuela sanctions authorities, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated Rosneft Trading S.A. (RTSA), the trading arm of Russian energy company Rosneft Oil...more