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Last week's major developments in sanctions - May 2nd to May 8th, 2022

For a detailed post about Russia-related sanctions developments you can check: Special Edition - New Sanctions Against Russia 🇷🇺

To see non-Russia- related previous weeks' updates you can check: Weekly Updates

Monday, May 2nd

  • Ten individuals and an entity came off the French list of sanctions targets as their designation periods expired.

  • OFAC issued Russia-related General License 30, authorizing transactions involving Gazprom Germania GmbH prohibited by Directive 3 under Executive Order 14024.

Tuesday, May 3rd

Wednesday, May 4th

  • OFSI added 63 entries to the list of financial sanctions targets under its Russia sanctions regime. (Here)

  • UK announced a ban on services exports, including management consulting, accounting and public relations, to Russia. (Here)

  • The EU announced its sixth sanctions package (not officially yet). (Here) The new package as announced in a press release includes:

    1. designation of high-ranking military officers and other individuals who committed war crimes in Bucha and who are responsible for the inhuman siege of the city of Mariupol;

    2. "de-SWIFTing" Sberbank and two other major banks;

    3. banning three big Russian state-owned broadcasters from EU's airwaves; and

    4. Banning accountants, consultants and spin doctors from providing their services to Russian companies.

Thursday, May 5th

  • DOJ announced the execution of a seizure warrant for freezing a yacht owned by sanctioned Russian oligarch Suleiman Kerimov in Fiji. The seizure warrant found that the yacht in question was subject to forfeiture based on probable cause of violations of U.S. law, including the International Emergency Economic Powers Act (IEEPA), money laundering and conspiracy. (Here)

  • issuing Russia-related General License 7A (authorizing overflight payments, emergency landings, and air ambulance services), General License 26A, (replacing General License No. 26), General License 31(authorizing certain transactions related to patents, trademarks, and copyrights ), and General License 32 (authorizing the wind down of transactions involving Amsterdam Trade Bank NV). It also amended several FAQs and published FAQ 1032 which is about Afghanistan-related transactions with TKB.

  • The UK designated Evraz PLC, major manufacturer of Russian steel. (Here, press release) Concurrently, OFSI issued General License - INT/2022/1710676 which allows for the continuation of business operations of three of the North American Subsidiaries of Evraz OLC: Evraz North America plc, Evraz Inc. NA, and Evraz Inc. NA – Canada.

Friday, May 6th

  • OFAC designated BLENDER.IO, a virtual currency mixer which is used by the Democratic People’s Republic of Korea to support its cyber activities and money-laundering of stolen virtual currency, under its Cyber sanctions program. (Here, Treasury's press release, Department of State's press release) OFAC also identified four additional virtual currency wallet addresses used by the Lazarus Group and added them to the Lazarus Group entry on the SDN list.

Sunday, May 8th

  • I cannot remember OFAC taking any actions over the weekend! This week that changed! OFAC surprised everyone by announcing a considerable expansion of sanctions against Russia. (Here, Treasury's press release) The new sanctions are:

    1. Blocking sanctions against 33 individuals (including board members of some Russian banks), 22 entities (including a bank, a weapons manufacturer, and tv stations), and several vessels;

    2. A determination was made pursuant to Section 1(a)(i) of Executive Order 14024. (Here) This determination allows for sanctions to be imposed on any individual or entity determined to operate or have operated in the accounting, trust and corporate formation services, and management consulting sectors of the Russian Federation economy and expands the United States’ ability to swiftly impose additional economic costs on Russia for its war of choice in Ukraine. Please note that a designation of a person is still needed;

    3. A determination was made pursuant to section 1(a)(ii) of executive order 14071. (Here) By doing so OFAC prohibited the export, reexport, sale, or supply, directly or indirectly, from the United States, or by a U.S. person, wherever located, to any person located in the Russian Federation in the following sectors:

      1. Accounting,

      2. Trust and corporate formation; and

      3. Management consulting

  • To mitigate the unintended impacts of the new sanctions OFAC issued Russia-related General License 25A, General License 33, General License 34, and General License 35 and published several new Frequently Asked Questions.

  • The Department of State also announced several visa restrictions against Russian and Belarusian individuals. (Here) The Department of State also published a Fact Sheet regarding today's actions. (Here)


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