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Last week's major developments in sanctions - June 10th, 2024, to June 14th, 2024

Monday, June 10

Tuesday, June 11

Wednesday, June 12
  • OFSI published Personal Staff Payments Licensing Guidance which describes how OFSI looks at license requests concerning personal staff (e.g., chefs, cleaners drivers, etc.) payments. (Here)

  • Right before the G7 leaders summit in Italy, the U.S. government announced major sanctions against Russia.

  1. OFAC published a Determination pursuant to section 1(a)(ii) of EO 14071 which prohibits the provision of certain technology and software services to Russia from September 12, 2024. (Here)

  2. OFAC and the State Department designated more than 300 individuals and entities under the authority granted in EO 14024. Among the designated persons are the Moscow Exchange, the National Clearing Center, the National Settlement Depository, and the Russian National Reinsurance Company. (The Department of the Treasury's Press Release, the Department of State's Press Release, and the Department of State's Fact Sheet)

  3. To mitigate the unintended impacts of these designations OFAC issued many general licenses. (Here)

  4. To further explain actions on this day, OFAC published and updated many FAQs. (Here)

  5. OFAC updated its Compliance Advisory for Foreign Financial Institutions on OFAC Sanctions Authorities Targeting Support to Russia’s Military-Industrial Base. An important escalation of U.S. sanctions against Russia took place through this update. Based on the updated version of the Advisory "foreign financial institutions that conduct or facilitate any significant transaction or provide any service involving any person blocked pursuant to E.O. 14024 now risk being sanctioned by OFAC, unless they are solely facilitating permissible transactions such as those related to food, agriculture, medicine, energy, and telecommunications." In other words, OFAC introduced "secondary sanctions" risk for all designated entries with [RUSSIA-EO14024] tag. Of note is that based on the current language of the Advisory provision of "any service" (i.e., not necessarily significant) to a person designated with [RUSSIA-EO14024] tag is now enough for OFAC's designation. (Here)

  6. BIS expanded its restrictions by expanding the scope of items identified under two EAR supplements that are subject to the EAR’s Russian and Belarusian industry sector sanctions; imposing a “software” license requirement for certain EAR99-designated “software” when destined to or within Russia or Belarus; and narrowing the scope of commodities and software that may be authorized for export, reexport, or transfer (in-country) to or within Russia or Belarus under License Exception Consumer Communications Devices (CCD). (Here)

  7. BIS added five entities and eight addresses (for the first time) to its Entity List. (BIS press release) The addition of addresses can cause major challenges for those who must comply due to the difficulties associated with screening addresses.

  • The U.S. Department of Justice brought charges against two U.S. citizens for operating a scheme to illegally export nearly half a million dollars’ worth of snowmachines and associated parts from the United States to Russia without the required licenses and approvals, in violation of U.S. export laws. (Here)

Thursday, June 13
  • France imposed asset-freezing sanctions against an individual and an entity under its autonomous counter-terrorism sanctions regime. (Here)

  • OFSI imposed asset-freezing sanctions against two entities under its Central African Republic sanctions regime. (Here)

  • OFSI imposed asset-freezing sanctions against seven individuals and 35 entities under its Russia sanctions regime. (Here, and press release)

  • BIS imposed a civil penalty of $285,000 against Sapphire Havacilik San Ltd. STI (Sapphire), an aviation company headquartered in Ankara, Türkiye, to resolve violations of the Export Control Reform Act of 2018, related to Sapphire's private charter flights involving a U.S.-origin Gulfstream aircraft into Russia without a required BIS license. (Here)

Friday, June 14

Recommendations for the week
  • Check out the G7 Leaders' Communiqué which states that they "decided to make available approximately USD 50 billion [for supporting Ukraine’s fight for freedom and its reconstruction] leveraging the extraordinary revenues of the immobilized Russian sovereign assets."

  • Be on the lookout for an exciting tool by Sanctions Expert later this week. 🥁🥁🥁


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